It was sufficient for the government to show that the checks were sent through the mail as part of the overall scheme of mail fraud. The government clearly met this burden. D. Evidence re Money Laundering for Counts Seventy-Three through Eighty-Eight Bohn was charged in Counts seventy-three through eighty-eight with money laundering to promote mail fraud and to conceal the proceeds of that mail fraud in violation of 18 U.S.C. § 1956(A)(2)(a), (A)(2)(b)(l). Bohn contends that the evidence was not sufficient to prove money laundering because the government failed to prove that he had “actual subjective knowledge” that the money used in the alleged money laundering transaction was derived from an unlawful source. See United States v. Heaps, 39 F.3d 479, 484 (4th Cir.1994) (<HOLDING>). Bohn’s reliance on Heaps is misplaced. In
holding in the context of the criminal false claims act that to prove falsity the government only had to prove that the statement was known to be untrue at the time the defendant made it holding that the government must prove actual subjective knowledge and that a defendant may not be convicted on just what he should have known holding that the government need not prove actual notice to the prisoner holding that the issue of defendants actual knowledge should not be resolved on summary judgment but should be left to the trier of fact holding that the creditor must prove the elements of actual fraud