United States of America v. Paul Williams Anti

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Argued April 23, 2025
Decided June 5, 2025
Before
DAVID F. HAMILTON, Circuit Judge
THOMAS L. KIRSCH II, Circuit Judge
CANDACE JACKSON-AKIWUMI, Circuit Judge
No. 24-2064
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
PAUL WILLIAMS ANTI,
Defendant-Appellant.
Appeal from the United States District
Court for the Western District of
Wisconsin.
No. 3:23-cr-00022-wmc-1
William M. Conley,
Judge.
O R D E R
Paul Williams Anti pleaded guilty to one count of money laundering under
18 U.S.C. § 1956(h) for his role in a scheme to defraud various organizations out of
millions of dollars. The district court sentenced Anti to 72 months in prison and ordered
him to pay more than $2.4 million in restitution to the victims. Anti appeals, arguing
that the district court sentenced him based on inaccurate information—the scope of his
knowledge about the scheme, his role in the scheme, and his familiarity with such
schemes as a result of his growing up in Ghana. We affirm because the record does not
show the court relied on inaccurate information when it sentenced Anti.
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with Fed. R. App. P. 32.1

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No. 24-2064 Page 2
Background
In October 2020, Anti participated in a conspiracy to defraud multiple businesses
and organizations throughout the United States of more than $7 million. Unknown
individuals gained access to the emails of the businesses and altered invoices to direct
payments to bank accounts controlled by Anti and other conspirators. One Wisconsin-
based organization lost $2.4 million to the fraud scheme.
Anti, for his part, used false identification documents to open and manage four
bank accounts that received approximately $1 million of the $2.4 million stolen from the
Wisconsin organization. Anti also controlled ten other bank accounts that he used to
launder approximately $3.9 million stolen from the other victims. Under the scheme,
Anti would immediately transfer to other bank accounts those payments by victims that
had been redirected to the accounts he controlled.
Anti was caught when the FBI interviewed employees of the Wisconsin-based
organization and obtained bank records of the accounts where the money was
redirected. Investigators discovered that the accounts were opened and managed by
someone using a stolen identity. Anti had opened the accounts with a fraudulent
driver’s license. Also, while working at a Connecticut assisted-living facility under a
false name, Anti redirected correspondence from the bank accounts to the mailbox of
one of the facility’s patients. Investigators quickly matched Anti to the photograph on
the fraudulent driver’s license.
In February 2024, Anti pleaded guilty to one count of money laundering under
18 U.S.C. § 1956(h). In his plea agreement, he agreed that his role in the scheme was to
launder the illegal proceeds. He acknowledged that while he did not know the details
of the scheme, the government could prove that he knew the funds were fraudulently
obtained and that he had no legal right to the funds deposited in his bank accounts. He
agreed to pay restitution for the losses related to the scheme.
The probation office prepared a Presentence Investigation Report that
incorporated objections and clarifications from Anti and the government. The PSR
calculated a guideline range of 70 to 87 months in prison based on a total offense level
of 27 (given a total loss amount of $3.8 million) under U.S.S.G. § 2S1.1(a)(2) and
§ 2B1.1(b)(1)(J), and a criminal history category of I.
In a sentencing memorandum, Anti objected to the total loss calculation. Without
actually saying how much money he actually kept in this case, he asserted that money

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No. 24-2064 Page 3
launderers “typically” retain a small percentage, borrowing a figure of two percent
from the government’s position in another case in the same district. On that basis Anti
argued he should not be held responsible for the entire amount that passed through his
bank accounts. He argued for a 46-month sentence based on this being his first offense,
his low risk of reoffending, and the lower sentences received by similarly situated
defendants. He maintained that he played a “discrete role,” merely moved money
around, and did not know where the money came from or where it ended up. He did
not argue, however, that he was entitled to a mitigating-role reduction under U.S.S.G.
§ 3B1.2.
At the sentencing hearing, the court accepted the proposed guideline range of 70
to 87 months and rejected Anti’s argument that his role in the scheme was limited.
Impatient that Anti had not been more forthcoming with certain details about the
scheme (such as how his co-conspirators gained access to the victims’ accounts and how
much of the funds he retained), the court said, “the defendant knows more than he’s
willing to disclose, and there has to be some consequence for that.” The court noted the
problem with the defendant’s argument about keeping a small percentage without
coming forward with actual evidence: “I’m not going to assume at this point for the
defendant’s benefit that he got some small percentage as a payment as a money
launderer. That’s an interesting theory, but it’s not something that’s before the court.”
The court went on: “I don’t know how [Anti] gets the benefit of being a small player
and a cog if he’s not willing to work to at least describe how those cogs move, and
there’s got to be a consequence for having engaged in this kind of level of fraud for this
long.” The court added that, even if Anti lacked knowledge of the broader scheme and
retained only a small percentage of the money, he was a key actor in the fraud because
his laundering scheme was sophisticated and he “legitimized the entire operation by
finding local addresses [and] moving large sums of money through his own accounts.”
It would be a “disservice,” the court stated, for the sentence not to reflect Anti’s role as a
key player in the scheme.
The court’s skepticism toward Anti’s argument continued through the allocution,
during which Anti denied defrauding any victims and insisted that he merely followed
the orders of unknown individuals who called him. Anti maintained that he was misled
by his co-conspirators and did not foresee the consequences of his actions because of his
“African background.” At that point, the judge interrupted Anti and expressed disbelief
that he could have been unaware about the source of the funds and intentions of his co-
conspirators. In an apparent off-the-cuff response, the judge then asserted—
mistakenly—that Ghana “is one of the biggest economies in the world.” Ghana may be

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No. 24-2064 Page 4
a “third-world economy,” the judge noted, but then added that “all kinds of economic
activity” goes on there and that “it was a known center for this kind of fraud.” Based on
the time that Anti spent living in Accra, the judge expressed doubt that Anti “didn’t
know what was going on” in the greater scheme.1 Anti did not object to any of this line
of commentary.
The judge adopted the PSR and ultimately sentenced Anti to 72 months in prison
and three years of supervised release. The judge also ordered him to pay $2.4 million in
restitution. Addressing Anti’s background and education under the factors in 18 U.S.C.
§ 3553(a), the judge again misspoke about the size of Ghana’s economy: “He reports
spending his upbringing and early years living in Ghana, the largest economy in Africa,
then moving to the United Kingdom where he continued his education.” The judge also
considered Anti’s use of false identification documents, his abuse of his position as a
caretaker for the elderly, his efforts to conceal his identity, and the amount of
fraudulent proceeds that passed through his bank accounts. The judge found that,
although it was unknown whether Anti played a role in defrauding the victims, he was
nonetheless a key player because he maintained a sophisticated system of money
laundering that caused large losses for the victims that were not recovered.
Analysis
On appeal, Anti argues that the judge procedurally erred by sentencing him
based on inaccurate information. He argues that the judge wrongly assumed that he
knew more about the scheme than he had disclosed, that he was a key player in the
scheme, and that he must have known about the intentions of his co-conspirators and
the illegal source of the funds deposited into his account because he is Ghanian.
To challenge his sentence on the grounds that it was based on such a procedural
error, Anti must show that that court relied on inaccurate information in sentencing
him. United States v. Campbell, 99 F.4th 957, 960 (7th Cir. 2024). We review de novo
whether the court committed any significant procedural error, and we review for clear
error the district court’s underlying factual findings. United States v. Kowalski, 103 F.4th
1273, 1277–78 (7th Cir. 2024). If there are no procedural errors, we review for abuse of
discretion the substantive reasonableness of the sentence. Id.
1 According to the PSR, Anti lived in Accra between the ages of 11 and 23 before
leaving to study in the United Kingdom. He later returned to Accra at an unspecified
time.

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No. 24-2064 Page 5
I. Anti’s Knowledge of the Fraud Scheme
Anti argues that the court procedurally erred by assuming that he knew more
about the scheme than he had disclosed. He contends that the court relied on this
assumption to infer that he was a key actor in the scheme. In support, he points to the
court’s comment that “there has to be some consequence” for his not disclosing more
information about the conspiracy.
Defendants have a due process right to be sentenced based on accurate
information. E.g., United States v. Harris, 118 F.4th 875, 887 (7th Cir. 2024). But a district
court also has leeway to make common-sense inferences from the record.
See United States v. Moody, 915 F.3d 425, 431 (7th Cir. 2019).
Here the court was entitled to infer from the record that Anti knew more than he
had disclosed. The indictment, for instance, described his role in the scheme as
“designed to conceal the source, control, ownership, and location of proceeds that were
derived from a fraud-scheme” and “designed to help conceal his true identity and
avoid detection.” In addition, the plea agreement acknowledged that Anti may not have
known the details of the scheme, but the government could prove that he knew the
funds deposited into his accounts derived from unlawful activity. And the PSR, which
the court adopted, described how Anti participated in the scheme for years, received
fraudulent funds from organizations he did not work for, and transferred the
fraudulent funds to other bank accounts.
Given that Anti disclosed virtually nothing to the government about the scheme
in which he was significantly involved, the court acted within reason by inferring that
he must have possessed more knowledge about his own involvement, his co-
conspirators, and the amount of proceeds he kept, and by therefore discounting Anti’s
mitigation argument that he was a small cog in the larger fraudulent scheme. As the
court noted, Anti was entitled to stand on his right not to provide further information to
the government and the court, but he was not entitled to benefit from his silence by
requiring the court to adopt his mitigation arguments based on speculation.
See Sentencing Tr. at 10–12.
The record further supports the court’s view that Anti’s role as a money
launderer was a crucial part of the scheme. As the judge explained, Anti’s role was
large: He laundered approximately $3.8 million of the $7 million lost by the victims
through fourteen bank accounts that he controlled. Anti’s operation was also
sophisticated. He used multiple fake identification documents to set up the bank

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No. 24-2064 Page 6
accounts and then routed the mail from those bank accounts to his elderly patient’s
mailbox. To hide his activities, he used a false name while he worked at the assisted
living facility. What’s more, Anti does not meaningfully dispute the judge’s observation
that he was a key actor because he “legitimized the entire operation” by laundering so
much money.
II. Anti’s Nationality
Anti also argues that the court relied on inaccurate and stereotypical beliefs
about Ghana—the size of its economy and the prevalence of fraud there—to conclude
that he knew about the illegal source of the funds and could not have been misled by
the other fraudsters. Anti points to the court’s statements that he must have known he
was participating in fraud scheme because he is from Ghana, “one of the biggest
economies in the world” that is a “known center for this kind of fraud.”
We begin with our standard of review when evaluating this argument. Anti did
not object to the judge’s comments at sentencing about his nationality, an omission that
raises questions about this court’s standard of review. Earlier cases from this court
suggest that the standard under such circumstances would be for plain error.
See, e.g., United States v. Trujillo-Castillon, 692 F.3d 575, 578 (7th Cir. 2012). But we think
the better view is conveyed in our more recent cases that point to a de novo standard
because the alleged error occurred during the court’s explanation of its sentencing
decision. When the alleged error is created by the court’s ruling itself, without an
opportunity to object, a defendant like Anti need not assert an “exception” to the ruling
to preserve the issue for review. United States v. Martin, 122 F.4th 286, 289–90 (7th Cir.
2024) (applying and explaining background of this principle); see also United States v.
Coe, 992 F.3d 594, 597 (7th Cir. 2021) (de novo review of defendant’s claim that judge
impermissibly considered race during sentencing); United States v. Beltran-Leon, 9 F.4th
485, 491 (7th Cir. 2021) (de novo review of defendant’s claim that judge impermissibly
considered ethnicity during sentencing).
As for the merits, of course a district court may not consider national origin
when it determines a sentence. Trujillo-Castillon, 692 F.3d at 579. But there is a “very fine
line of demarcation separating presentencing statements regarding a defendant’s
relationship with a country or its residents who have engaged in similar criminal
activity there and statements concerning the race or national origin of the defendant
which would violate his due process guarantees.” Id., quoting United States v. De La
Cruz, 870 F.2d 1192, 1198 (7th Cir. 1989).

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Here, the court came close to that line when it expressed incorrect
generalizations about Ghana’s economy. Ghana is not among the top ten largest
economies in Africa. See Adekunle Agbetiloye, 10 Largest Economies in Africa in 2024 –
IMF, Bus. Insider Afr. (Apr. 22, 2024), https://africa.businessinsider.com/local/markets/
10-largest-economies-in-africa-in-2024-imf/3t0f1j1. Anti’s Ghanaian background, in and
of itself, did not initiate him in the workings of fraud schemes or enable him to foresee
the consequences of his actions.
But as we read this transcript, the court ultimately did not rely on these
inaccurate and inappropriate comments about Anti’s nationality. His case differs from
Trujillo-Castillon, in which we vacated the sentence where the judge appeared to rely on
the defendant’s Cuban heritage at sentencing. Here, it was Anti who first injected his
nationality into the sentencing hearing when he argued that he could not foresee the
consequences of his actions because of his “African background.” The judge’s
statements stemmed from disbelief that Anti could argue that his Ghanaian background
would prevent him from knowing what he was getting into. In context, it is apparent
that the judge based Anti’s sentence not on his nationality but on his key role as a
money launderer in the scheme, his abuse of his position as a caretaker for the elderly,
and the amount of loss the victims suffered. Still, this case serves as a caution that
district judges must tread very carefully when responding to a defendant’s invocation
of race or nationality. Responses can too easily be misunderstood as reliance on
impermissible factors.
Finally, Anti’s within-guidelines sentence was substantively reasonable. A
within-guideline range sentence is presumptively reasonable, see Kowalski, 103 F.4th at
1280, and Anti has given us no reason to overcome the presumption.
AFFIRMED

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