5th Cir. Pattern Jury Instr. (Criminal) 2.26

18 U.S.C. § 554

Title 18, United States Code, Section 554, makes it a crime for anyone to knowingly

[fraudulently] export [send] [attempt to export] [attempt to send] any merchandise [article or

object] from the United States contrary to any law or regulation of the United States.

For you to find the defendant guilty of this crime, you must be convinced that the

government has proved each of the following beyond a reasonable doubt:

First: That the defendant knowingly [fraudulently] exported [sent] [attempted to export]

[attempted to send] merchandise as described in the indictment;

Second: That the defendant’s exportation [sending] was contrary to (describe the law[s] or

regulation[s] in detail); and

Third: That the defendant knew the exportation [sending] of the merchandise was contrary

to law or regulation.

“Merchandise” means goods, wares, and chattels of every description, and includes

merchandise the exportation of which is prohibited.

To “export” means to send or carry from the United States to another country.