the court should not have treated all of Target Oil’s investor funds obtained during the conspiracy as “proceeds” because the government needed to prove that the overt acts of fraud directly generated the funds Vernon claimed. But the statutory language — defining proceeds to include property obtained “directly or indirectly” from the crime — and our criminal forfeiture cases endorse no such stringent standard. For instance, in Michael and Christopher’s appeal, we held that the investor money that funded the purchase of the cashier’s checks constituted forfeitable proceeds because “the transactions ‘all resulted directly or indirectly from a conspiracy to commit fraud.’ ” Smith, 749 F.3d at 488-89 (citation omitted); see also United States v. Warshak, 631 F.3d 266, 332 (6th Cir.2010) (<HOLDING>). Notably, Smith did not require evidence
holding that the entirety of litigation settlement proceeds was taxable income to client not net after payment of attorney fees holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate holding entirety of the businesss revenue constituted forfeitable proceeds that resulted whether directly or indirectly from the conspiracy holding that regardless of whether the property was held as tenants in common or by the entirety the husband was entitled to hold property as a homestead holding that repeated appropriations of the proceeds of certain fees constituted a ratification of agency policy