MANION, Circuit Judge.
Ali Erdogan Gurtunca, also known as Ali Turk, worked during the years 1978-1981 as a self-employed consultant-loan broker. Gurtunca would tell potential clients that he had connections with foreign sources (usually Middle Eastern) who had large amounts of money available to loan at low interest rates. Gurtunca would tell the clients that before he could arrange a loan, the client would have to pay him in advance to cover items such as fees and...
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