The author discusses the application of the federal forfeiture provisions in the Continuing Criminal Enterprise Statute when property subject to forfeiture is transferred to a third party prior to an indictment. After a general discussion of section 848, the comment centers around the decisions of United States v. Veon and United States v. Long. The author advocates adherence to the Veon result which does not permit forfeiture once the property is transferred, before indictment, to a third party.
John A. Gill,
Continuing Criminal Enterprise Statute: Effect of Forfeiture Provisions on Third Parties,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol22/iss1/6