“Sophisticated means” is defined as: especially complex or especially intricate offense conduct pertaining to the execution or concealment of an offense. For example, in a telemarketing scheme, locating the main office of the scheme in one jurisdiction but locating soliciting operations in another jurisdiction ordinarily indicates sophisticated means. Conduct such as hiding assets or transactions, or both, through the use of fictitious entities, corporate shells, or offshore financial accounts also ordinarily indicates sophisticated means. U.S.S.G. § 2B1.1, comment. (n.8(B)). Although we have not fully delineated what qualifies as “sophisticated means,” we have held “sophisticated means involves more than minimal planning.” United States v. Humber, 255 F.3d 1308, 1314 (11th Cir.2001) (<HOLDING>). Based on the repetition and complexity of
holding that more than notice to a defendant is required holding that appellate court should afford due deference to district court determination that defendant engaged in more than minimal planning holding that to grant a new trial the error must be more than harmless holding even minimal payment required by the icrp could be beyond the debtors means holding sophisticated means and the nowdefunct more than minimal planning enhancements could be applied cumulatively