O120 Procurement of Citizenship or Naturalization Unlawfully

The Defendant can be found guilty of a violation of section 1425(a), only if all the following facts are proved beyond a reasonable doubt:

(1) the Defendant knowingly [procured] [attempted to procure];

(2) contrary to law;

(3) the naturalization of any person, or documentary or other evidence of naturalization or citizenship[.] [; and]

[(4) the Defendant did so [to facilitate an act of international terrorism] [to facilitate a drug trafficking crime].]

The Defendant can be found guilty of a violation of section 1425(b), only if all of the following facts are proved beyond a reasonable doubt:

(1) the Defendant [for himself] [for another person not entitled thereto] knowingly [issued, procured, obtained, applied for], [attempted to procure or obtain] [naturalization or citizenship, or a declaration of intention to become a citizen, or a certificate of arrival or any certificate or evidence of nationalization or citizenship, documentary or otherwise, or duplicate copies of the foregoing];

(2) [the Defendant is not entitled to naturalization or citizenship] [the other person is not entitled to naturalization or citizenship]; and

(3) [the Defendant knows he or she is not entitled to naturalization or citizenship]; [the Defendant knows the other person is not entitled to naturalization or citizenship[.] [; and]

[(4) the Defendant did so [to facilitate an act of international terrorism] [to facilitate a drug trafficking crime].]