In United States v. Soto, --- F.3d ---, No. 18-10070 (9th Cir. 2019), the Court affirmed the district court's forfeiture order for substitute property.
The defendant pleaded guilty to one count of
attempting to export ammunition from the United States, in
violation of 18 U.S.C. § 554, and one count of conspiracy to
export firearms and ammunition, in violation of 18 U.S.C.
§ 371.
Although §§ 371 and
554(a) are not expressly mentioned in the federal forfeiture
statutes, the Court concluded forfeiture was authorized under 18 U.S.C. § 924(d)(1), which covers forfeiture of firearms and ammunition "involved" in a federal
crime. Further, the district court properly ordered forfeiture of substitute property under 28 U.S.C. § 2461(c) and 21 U.S.C. § 853(p).
