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    In the
    United States Court of Appeals
    For the Seventh Circuit
    
    No. 95-2496
    
    UNITED STATES OF AMERICA,
    
    Plaintiff-Appellee,
    
    v.
    
    GREGORY D. WILSON,
    
    Defendant-Appellant.
    
    
    Appeal from the United States District Court
    for the Central District of Illinois.
    No. 95 CR 30013--Richard Mills, Judge.
    
    
    ARGUED APRIL 1, 1996--DECIDED OCTOBER 17, 1996
    
    
       Before CUMMINGS, EASTERBROOK and ROVNER,
    Circuit Judges.
    
       ROVNER, Circuit Judge.  Illinois security broker Gregory
    Wilson conducted a Ponzi scheme that defrauded forty-eight
    victims of more than three million dollars. Representing to
    investors that their funds were being placed into certifi-
    cates of deposit, annuities, and mutual funds, Wilson ac-
    tually deposited the funds into a personal checking account
    and used them both for personal expenses and to cover
    interest and dividend payments owed to previous investors.
    After federal agents uncovered the scheme, Wilson pled
    guilty to charges of mail fraud and money laundering.
    
       Wilson was then sentenced under the 1994 United States
    Sentencing Guidelines. The charges of mail fraud and of
    money laundering each produced an offense level of 23
    under Guidelines sections 2F1.1 and 2S1.1 respectively.
    Because the district court did not group the counts to-
    gether (U.S.S.G. sec. 3D1.2), Wilson received a two-level
    multiple count adjustment under section 3D1.4, so that
    his adjusted offense level was 25. That level was reduced
    by three levels for Wilson's timely acceptance of responsi-
    bility. With a criminal history category of I, Wilson's
    sentencing range was 41 to 51 months. The district court
    sentenced Wilson at the top of that range to 51 months
    of incarceration. The court also ordered Wilson to pay
    restitution in the amount of $3,114,334. On appeal, Wilson
    argues that the court erred in refusing to group the mail
    fraud and money laundering charges together; he also
    challenges the order of restitution./1
    
    I.
    
       Guidelines section 3D1.2 deals with the grouping of "close-
    ly related counts." It provides that "[a]ll counts involving
    substantially the same harm shall be grouped together
    into a single Group" and then sets out in four subsec-
    tions the circumstances under which that condition is met:
    
    (a) When counts involve the same victim and the
    same act or transaction.
    
    (b) When counts involve the same victim and two
    or more acts or transactions connected by a com-
    mon criminal objective or constituting part of a
    common scheme or plan.
    
    (c) When one of the counts embodies conduct that
    is treated as a specific offense characteristic in,
    or other adjustment to, the guideline applicable
    to another of the counts.
    
    (d) When the offense level is determined largely on
    the basis of the total amount of harm or loss,
    the quantity of a substance involved, or some
    other measure of aggregate harm, or if the of-
    fense behavior is ongoing or continuous in nature
    and the offense guideline is written to cover such
    behavior.
    
    U.S.S.G. sec. 3D1.2. As the underlying facts are not disputed
    and our task primarily is to interpret the guideline, we
    review the district court's decision not to group the mail
    fraud and money laundering counts de novo. United States
    v. McDuffy, 90 F.3d 233, 235 (7th Cir. 1996).
    
       The central purpose of this section, as the Eleventh Cir-
    cuit has pointed out, "is 'to combine offenses involving
    closely related counts' " (United States v. Mullens, 65
    F.3d 1560, 1564 (11th Cir. 1995) (quoting United States
    v. Harper, 972 F.2d 321, 322 (11th Cir. 1992) (per curiam))
    (emphasis in Harper), cert. denied, 116 S. Ct. 1337 (1996)),
    and Wilson's convictions for mail fraud and money launder-
    ing without question meet that criterion. All of the money
    that Wilson laundered was money defrauded from his in-
    vestors, so "[w]ithout the fraud there would have been
    no funds to launder." Mullens, 65 F.3d at 1564. Moreover,
    the money laundering took place in an effort to conceal
    the fraud and keep the entire scheme afloat. For example,
    Wilson would take money that he received from his in-
    vestors and purchase cashier's checks to make payments
    to earlier investors, in classic Ponzi fashion. See Informa-
    tion Count II; Plea Agreement at 3-4; Plea Hearing Tr.
    39-40; Presentence Report para. 15. The use of a cashier's
    check concealed the source of the money (his personal
    bank account) and helped keep the fraudulent scheme
    afloat by lulling investors into a false sense of security./2
    (Indeed, the authorities were alerted to the scheme when
    Wilson made the mistake of paying one of his investors
    with a personal check. Presentence Report para. 15.) Wilson's
    commission of mail fraud arose from similar efforts to con-
    ceal the scheme: each month he would mail fictitious finan-
    cial statements to investors purporting to reflect the
    status of their funds. Plea Agreement at 3-4. In this way,
    "both the fraud and the money laundering were integral
    cogs in continuing the scheme." Mullens, 65 F.3d at 1564.
    Accord United States v. Leonard, 61 F.3d 1181, 1186 (5th
    Cir. 1995).
    
       The mail fraud and money laundering counts therefore
    should have been grouped. It is noteworthy that subsec-
    tion (d) of the guideline identifies a number of offenses
    that either are or are not to be grouped under that par-
    ticular subsection, and offenses governed by Guidelines
    sections 2F1.1 and 2S1.1 are among those identified as
    appropriate for grouping. Grouping may not be automatic
    for these offenses simply because they are listed (see
    Harper, 972 F.2d at 322), but the two offenses with which
    we are concerned here also satisfy the standard outlined
    in application note 6: "Counts involving offenses to which
    different offense guidelines apply are grouped together
    under subsection (d) if the offenses are of the same gen-
    eral type and otherwise meet the criteria for grouping
    under this subsection." Broadly speaking, they are "of the
    same general type,"/3 and the offense level for each "is
    determined largely on the basis of the total amount of
    harm or loss" as subsection (d) envisions. See United
    States v. Adams, 74 F.3d 1093, 1102 n.12 (11th Cir. 1996)
    ("Fraud and money laundering convictions . . . can be
    grouped under U.S.S.G. sec. 3D1.2(d).").
    
       We reject the government's contention that these of-
    fenses are inappropriate for grouping because they involve
    different victims and thus different harms. Whether the
    offenses involve different victims is, as the background
    commentary notes, "[a] primary consideration" in the group-
    ing decision. There is also a line of authority, on which
    the district court relied, observing that the victim of mail
    fraud is the person defrauded, while the victim of money
    laundering is society at large. See, e.g., United States v.
    Kunzman, 54 F.3d 1522, 1531 (10th Cir. 1995) (following
    United States v. Johnson, 971 F.2d 562, 576 (10th Cir.
    1992)); United States v. Lombardi, 5 F.3d 568, 570 (1st
    Cir. 1993). In the abstract, that may be true. Yet, when
    the defendant is convicted of laundering the proceeds of
    his fraud in order "to conceal or disguise the nature, the
    location, the source, the ownership, or the control of the
    proceeds," as Wilson was here (see sec. 1956(a)(1)(B)(i)), there
    is intuitive force to the argument that the victim of the
    fraud is also a victim of the transaction designed to hide
    or "cleanse" the funds of which she was defrauded./4 More
    to the point, the money laundering in this case served
    to perpetuate the very scheme that produced the laun-
    dered funds, as we have already explained. The Fifth Cir-
    cuit found this point dispositive in a similar case:
    
    [T]he money laundering offense was not "ancillary"
    here. There was a single, integrated scheme to ob-
    tain money from the elderly victims and to use that
    money to facilitate the continuance of the scam. The
    activities can not be neatly separated . . . . By con-
    ducting financial transactions--paying callers, pur-
    chasing leads, paying phone bills--with the victim's
    money for the purpose of bilking more people out of
    $395.50 each, the group of targeted victims became
    the victim of the money laundering activity as well
    as the fraud scheme. In this case, the district court
    properly found that the money laundering and fraud
    constituted part of the same continuing common crim-
    inal endeavor.
    
    Leonard, 61 F.3d at 1186 (following United States v. Cusu-
    mano, 943 F.2d 305, 312-13 (3d Cir. 1991) (affirming group-
    ing under subsection (b)), cert. denied, 502 U.S. 1036, 112
    S. Ct. 881 (1992))./5
    
       The fraud and money laundering counts therefore should
    have been grouped as indicated by subsection (d). The
    two-level increase in Wilson's offense level pursuant to
    section 3D1.4 was erroneous. We will, accordingly, vacate
    Wilson's sentence and remand for re-sentencing.
    
    II.
    
       Wilson also challenges the order of restitution. Although
    we have vacated Wilson's sentence, we are given no rea-
    son to believe that the district court will not order restitu-
    tion in the same amount when it resentences him, and
    so we will take up his challenge. Of course, our review
    of the restitution order is deferential. E.g., United States
    v. Lampien, 89 F.3d 1316, 1323 (7th Cir. 1996)./6 
    
       Although the district court enjoys broad discretion in
    requiring the defendant to compensate his victims (United
    States v. Viemont, 91 F.3d 946, 951 (7th Cir. 1996)) and
    full restitution is the norm, (United States v. Ahmad, 2
    F.3d 245, 247 (7th Cir. 1993)), the defendant must have
    "at least a hope" of complying with the court's restitu-
    tion order (United States v. Mahoney, 859 F.2d 47, 52 (7th
    Cir. 1988)), and we will vacate an order with which the
    defendant cannot possibly comply (Lampien, 89 F.3d at
    1323). Wilson contends that this is such an order. In his
    words:
    
    To order restitution of more than $3 million for an
    indigent defendant who has no assets, no income or
    prospect of income is unrealistic and excessive. There
    is absolutely no showing that this Defendant has any
    capability of repaying $3 million of restitution.
    
    Wilson Br. 22.
    
       The principal and fatal flaw in Wilson's argument is a fail-
    ure in proof. It is his burden to show that there is not
    even some hope of complying with the restitution order;
    it is not the government's burden or the court's to prove
    the contrary. See Viemont, 91 F.3d at 951; United States
    v. Murphy, 28 F.3d 38, 40 (7th Cir. 1994). Wilson's cur-
    rent indigence alone does not preclude the order (Viemont,
    91 F.3d at 951), and he points to nothing in the record
    demonstrating that his earning capacity makes restitution
    impossible (cf. Lampien, 89 F.3d at 1323-24). If future cir-
    cumstances bear out Wilson's argument, he of course re-
    tains the right to seek modification of the restitution order
    in the district court. Viemont, 91 F.3d at 952. At this
    juncture, however steep the restitution obligation, and
    however unlikely it may strike us that he will be able
    to honor it, Wilson has not presented the type of con-
    crete evidence that would demonstrate he has no hope
    of being able to comply. Under these circumstances, we
    have no basis to disturb the court's order.
    
    
    III.
    
       Because the fraud and money laundering convictions
    should have been grouped, and the two-level adjustment
    in Wilson's offense level pursuant to Guidelines section
    3D1.4 was therefore in error, we vacate Wilson's sentence
    and remand for resentencing. Finding no abuse of discre-
    tion in the district court's order that Wilson make restitu-
    tion in the amount $3,114,334, we affirm that order.
    
    AFFIRMED IN PART,
    VACATED IN PART, and REMANDED.
    
    
    FOOTNOTES
    
    
    /1
       Wilson additionally argues that the court lacked
    jurisdiction over him because he is a "free white male,"
    subject to the laws of the State of Illinois, but not those
    of the federal government. As we have previously ruled,
    this argument is without merit. United States v. Sloan,
    939 F.2d 499, 500-01 (7th Cir. 1991), cert. denied, 502 U.S.
    1060, 112 S. Ct. 940 (1992).
    
    
    /2
       Although the information to which Wilson pled guilty
    charged him only with financial transactions designed "to
    conceal or disguise the nature, the location, the source,
    the ownership, or the control of the proceeds" of the fraud
    (18 U.S.C. sec. 1956(a)(1)(B)(i)), the indictment that was
    dismissed upon entry of his plea also charged him with
    engaging in similar transactions "with the intent to pro-
    mote the carrying on of" the fraud (sec. 1956(a)(1)(A)(i)). See
    Presentence Report para. 3.
    
    
    /3
       Note 6 explains that "[t]he 'same general type' of of-
    fense is to be construed broadly, and would include, for
    example, larceny, embezzlement, forgery, and fraud."
    
    
    /4
       See the third example identified in application note 4
    as appropriate for grouping under subsection (b) of the
    guideline: "The defendant is convicted of one count of auto
    theft and one count of altering the vehicle identification
    number of the car he stole. The counts are to be grouped
    together."
    
    
    /5
       Our research located several other cases in which the
    district court grouped money laundering and fraud of-
    fenses, although in none of these cases did the court of
    appeals consider the propriety of the grouping. See United
    States v. Sokolow, 91 F.3d 396, 410 (3d Cir. 1996); United
    States v. Haun, 90 F.3d 1096, 1102 (6th Cir. 1996); United
    States v. Leahy, 82 F.3d 624, 638 n.20 (5th Cir. 1996);
    United States v. Massey, 48 F.3d 1560, 1568 (10th Cir.),
    cert. denied, 115 S. Ct. 2628 (1995). Conversely, in United
    States v. Cole, 988 F.2d 681, 684-85 (7th Cir. 1993), the
    district court did not group the securities fraud and mail
    fraud offenses together with the money laundering of-
    fenses, and because the issue was not raised, we affirm-
    ed the sentence without discussing whether the decision
    not to group these offenses was correct.
    
    
    /6
       After we heard oral arguments in this appeal, the
    President signed into law what is known as the Antiter-
    rorism and Effective Death Penalty Act of 1996, Pub. L.
    104-132, 110 Stat. 1214. Title II of that act adds a new
    provision to the criminal code mandating restitution for all
    property offenses, "including any offense committed by fraud or
    deceit." 18 U.S.C.A. sec. 3663A(c)(1)(A)(ii) (West Supp. July
    1996). However, the new provision affects sentencing proceedings
    only in cases in which the defendant was convicted on
    or after April 24, 1996, when the act became law. See 18
    U.S.C.A. sec. 2248 note (West Supp. July 1996) Wilson, of
    course, was convicted and sentenced well in advance of
    this date, so the provision has no effect on his case.
    
    
    

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