commingled in its corporate bank accounts, all Enterprise funds, up to the value of property subject to forfeiture, qualify as commingled substitute property pursuant to 21 U.S.C. § 853(p)(E). And because there is probable cause to believe that Enterprise generated visa fraud proceeds significantly in excess of $125,000, the approximate total amount held in the two Bowman accounts, these funds are subject to restraint in their entirety. Nor does it matter that the funds were subsequently transferred from Enterprise to third parties, ie., movants, as § 853(c) makes clear that title vests in the United States upon the commission of the crime and that funds cannot then be immunized from forfeiture by transfer to a third party. See 21 U.S.C. § 853(c); McHan, 345 F.3d at 271-72 (<HOLDING>). The funds were transferred to the Bowman
holding that scope of property subject to forfeiture is defined by the instrument creating an interest in the property recognizing that the government may seek a personal judgment specific property or substitute property holding that governments title to substitute property like subsection a property relates back to date of acts giving rise to forfeiture holding that the governments precluding plaintiff from building a mitigation bank on his property was not a taking because the governments authority predated plaintiffs property right holding that plaintiffs may have a property interest in real property