Read the following excerpt from a US court opinion:
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promotional and concealment money laundering require the government to prove that the defendant knowingly used the "proceeds” of an unlawful activity, Wilkes's analysis of Santos is applicable here. Cf. Dis, op. at 1100. 17 . The dissent’s reliance on the Fourth Circuit's opinion in United States v. Cloud, 680 F.3d 396, 407 (4th Cir.2012) is also misplaced. In defining and applying "essential expenses,” Cloud relies on the Santos plurality’s reasoning that the term "proceeds” excludes any payout to a co-conspirator. Id. at 403-09. We have not interpreted Santos so broadly, relying instead on Justice Stevens’s case-by-case approach. See, e.g., Wilkes, 662 F.3d at 549. Other circuits have likewise refused to interpret Santos as broadly as the Fourth Circuit. See Kratt, 579 F.3d at 562 ; Garland v. Roy, 615 F.3d 391, 402 (5th
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What is the most suitable continuation to the opinion? Your options are:
A. holding that facts that increase the maximum sentence a defendant faces must be proven to a jury beyond a reasonable doubt
B. holding that a sixfold increase in sentence involved no enhancement of sentence because harrisonphilpot was charged and convicted of conspiracy the extent of the conspiracy caused the tremendous increase in her sentence
C. holding that in pleading scienter arguing that the motive for defrauding investors was to increase the companys profits or to increase officer compensation is not sufficient
D. holding in the ineffectiveassistanceofcounsel context that any increase in a defendants sentence is prejudicial
E. holding that proceeds means profits only when imposing a money laundering count leads to a radical increase in the statutory maximum sentence and only when nothing in the legislative history suggests that congress intended such an increase
Reply with [A, B, C, D, E] only.