Volume 107 — Federal Reporter, Fourth Series

United States v. Ji Chaoqun, 107 F.4th 715 (7th Cir. 2024), is a decision by the United States Court of Appeals for the Seventh Circuit concerning 18 U.S.C. § 951, a criminal statute that imposes fines and imprisonment on agents of foreign governments who fail to register as such with the U.S. Department of Justice. The court ruled that a jury does not need to unanimously decide which specific act a foreign agent committed when charged under the statute and that the legal commercial transaction exception in 18 U.S.C. § 951(d)(4) serves as an affirmative defense, not an element of the offense.