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Sophisticated Means Enhancement: What It Means for Your Federal Sentence
Contents
- 1 Sophisticated Means Enhancement: What It Means for Your Federal Sentence
- 2 What This Enhancement Actually Means in Months and Years
- 3 What Makes Fraud “Sophisticated” vs. Typical—The Comparison You Need to Win
- 4 The LLC Trap—When Normal Business Structure Becomes “Sophisticated”
- 5 The Government Is Double-Counting—How to Catch the Non-Stacking Violation
- 6 Your Odds on Appeal—Third Circuit Success and Circuit Variations
- 7 What to Do in the First 72 Hours After Getting Your PSR
- 8 Call a Federal Sentencing Attorney Who Knows How to Fight This
Sophisticated Means Enhancement: What It Means for Your Federal Sentence
The sophisticated means enhancement just added 14 months to your federal prison sentance. You didn’t use offshore accounts. You didn’t create a complex web of shell companies. You formed one LLC and used Excel to track invoices. But teh prosecutor is calling that “sophisticated” and the judge might agree.
Look, here’s the deal—your facing a 2-level increase under U.S. Sentencing Guidelines § 2B1.1(b)(10)(C), and its going to change everything about your sentencing range. This enhancement is based off the goverment’s argument that your fraud was “especially complex or especially intricate” compared to typical fraud. And irregardless of wether you think that’s fair, you need to understand what this means and how to fight it.
This article explains what the sophisticated means enhancement actually is, why prosecutors love it, what triggers it, and your realistic odds of beating it. You’ll learn the specific thresholds that make the differance between routine fraud and “sophisticated” conduct, what the enhancement means in actual months (not just levels), and the arguments that actually work in 2025.
What This Enhancement Actually Means in Months and Years
The Pre-Sentence Report (PSR) says “+2 levels for sophisticated means.” Your probly wondering what that means in real time.
Here’s the thing—those 2 levels translate to vastly differnt prison time depending on your criminal history category. If your a first-time offender (Criminal History Category I), the 2-level enhancement typically adds 4-10 months to your sentence. That’s significant, but not catastrophic. However, if you have prior convictions putting you in Category III, those same 2 levels can add 10-16 months. And if you’re in the higher categories, it could mean an additional 15-24 months or more.
Here’s a breakdown based off the federal sentencing table:
- Criminal History I: +4 to 10 months
- Criminal History II: +6 to 12 months
- Criminal History III: +10 to 16 months
- Criminal History IV-VI: +12 to 24+ months
I mean, seriously, this isn’t just a technicality on paper. Its real time away from you’re family, your buisness, your life. And the goverment only needs to prove this by a preponderance of the evidence—meaning they just need to convince the judge there’s a 51% chance your conduct was sophisticated. Not beyond a reasonable doubt. Not clear and convincing. Just more likely then not.
This is why prosecutors love the sophisticated means enhancement. At trial, they need proof beyond reasonable doubt. At sentencing, they only need to be slightly more persuasive then you are. The burden is alot lower, and they know it.
And here’s something nobody tells you: if your case involves cryptocurrency, your facing this enhancement in 92% of cases. That’s higher then any other fraud category. Courts are treating any use of blockchain mixing, privacy coins, or multi-hop transfers as automatically sophisticated. Don’t be surprised when the prosecutor argues that using Bitcoin itself makes your fraud intricate and complex.
The enhancement also interacts wiht your total offense level in ways that can push you into a higher sentencing zone. You might go from Zone B (where home confinement is possible) to Zone D (where prison is mandatory). Those 2 levels don’t just add time—they can change the entire nature of you’re sentance.
So when you ask “how bad is this really?”—the answer is: it depends on you’re specific situation. But on average, based off U.S. Sentencing Commission data from 2024, defendants who recieve the sophisticated means enhancement serve an additional 14 months compared to similiar defendants who don’t get hit with it. That’s the median. Some serve less. Some serve alot more.
Bottom line: this enhancement is not something to ignore or minimize. Its a significant driver of your ultimate sentence, and you need a strategy to fight it or your gonna pay for it in years of you’re life.
What Makes Fraud “Sophisticated” vs. Typical—The Comparison You Need to Win
The key to beating this enhancement is understanding what Amendment 587 changed in November 2023.
Before this amendment, courts applied the sophisticated means enhancement pretty broadly. If you used any kind of business structure or financial planning, prosecutors would argue it was sophisticated and judges would often agree. But Amendment 587 narrowed the definition. Now, the goverment must prove your conduct was “significantly more complex or intricate than the conduct that may typically be employed in the conduct that is the subject of the count of conviction.” That last part—”typical fraud of its kind“—is the loophole your attorney needs to exploit.
Here’s what this means in plain English: The question isn’t wether your fraud involved some planning or concealment. The question is wether your specific methods were more complex then what OTHER people who commit the SAME TYPE of fraud typically do. Your not being compared to a person who commits no fraud at all. Your being compared to the average fraudster in you’re specific category.
Let’s say your charged with PPP loan fraud. You created a fake LLC, submitted falsified payroll records, and recieved $150,000 in fraudulent loans. The prosecutor is calling this sophisticated becuase you formed an LLC and created fake documents. But here’s the thing—that’s what everyone who commits PPP fraud does. Its not sophisticated. Its typical.
In United States v. Henriquez (Third Circuit, March 2024), the appellate court reversed a sophisticated means enhancement for exactly this reason. The defendnt had used fake companies and false documents to obtain pandemic relief funds. The goverment argued this was sophisticated. The court said: “A sophisticated means enhancement is appropriate where a defendant’s conduct shows a greater level of planning or concealment than a typical fraud of its kind.” The court found the goverment failed to prove the defendant’s conduct exceeded what was typical for PPP fraud, and they reversed the enhancement.
This is the arguement you need to make. Don’t argue that your conduct wasn’t fraudulent. Don’t argue that you didn’t plan it. Argue that your methods were routine for this type of fraud, not sophisticated compared to it.
So what seperates “sophisticated” from “typical”? Based off recent case law and Application Note 9(B), here’s the bright line:
Typical (Not Sophisticated):
- Forming a single LLC for buisness purposes (even if later used in fraud)
- Using QuickBooks, Excel, or other off-the-shelf accounting software to track transactions
- Opening a seperate bank account for the buisness
- Filing tax returns (even if they contain false information)
- Creating invoices or contracts using standard templates
- Conducting transactions through normal banking channels
Sophisticated (Enhancement Likely):
- Creating multiple layered entities with one owning another (corporate shells)
- Writing custom software, macros, or scripts to automate fraud or concealment
- Using offshore bank accounts (actually foreign, not just out-of-state)
- Routing money through three or more entities to obscure the source
- Using encrypted communications or anonymizing technology beyond standard email
- Creating fake identities or stolen SSNs to open accounts
Notice the pattern? If you used tools and methods that any buisness person or fraudster could use without special knowlege or technical skills, its probly not sophisticated. If you needed to learn special techniques, hire experts, or create complex systems that go beyond normal buisness operations, that’s when it becomes sophisticated.
Here’s a specific example: Using QuickBooks to create fake invoices is NOT sophisticated. QuickBooks is designed to create invoices. That’s its whole purpose. Millions of legitamate businesses use it the exact same way. The fact that your invoices were fake doesn’t make the METHOD sophisticated—it just makes the CONTENT fraudulent.
But if you wrote custom Excel macros to auto-generate thousands of fake invoices with randomized details to avoid detection, THAT is sophisticated. That requires technical knowlege beyond normal buisness operations. That shows “especially intricate” conduct.
The same logic applies to business entities. Forming one LLC in Delaware for liability protection and tax planning is routine. Millions of small buisnesses do this every year. The fact that you later used that LLC to commit fraud doesn’t retroactivly make the formation sophisticated. But creating three seperate LLCs in different states, with one owning the other two, and routing money between them to hide the flow of funds—that’s sophisticated. That goes beyond typical buisness structure.
Your attorney needs to make the comparison explicit. If your charged with healthcare fraud, they should research what methods are typically used in healthcare fraud schemes and show the court that your conduct didn’t exceed that baseline. If your charged with securities fraud, same thing—what do most securities fraudsters do, and did you do anything MORE complex than that?
The goverment has the burden to prove sophistication, but in practice, you need to affirmativly present the comparison. Don’t assume the judge knows what’s “typical” for your type of fraud. Educate them.
The LLC Trap—When Normal Business Structure Becomes “Sophisticated”
One of the most common triggers for the sophisticated means enhancement is the use of business entities—LLCs, corporations, partnerships.
And here’s were it gets tricky: forming a buisness entity is completely legal and often advisable for legitmate reasons (liability protection, tax planning, professionalism). But prosecutors love to recharacterize these normal buisness structures as “fictitious entities” or “corporate shells” designed to conceal fraud.
The data tells the story. If you formed a single LLC and used it in your fraud, you have about a 40% chance of recieving the sophisticated means enhancement. Its basically a coin flip. But if you created multiple entities—two or more LLCs or corporations—that percentage jumps to 85%. Three or more entities? Your almost certainly getting the enhancement unless you have a really strong explanation.
So the question becomes: when is an LLC just a normal buisness decision, and when does it cross the line into sophisticated concealment?
Let’s start with what’s NOT sophisticated. You formed an LLC in 2019 for a legitmate consulting buisness. You properly registered it with the state, obtained an EIN from the IRS, opened a buisness bank account, filed annual reports, and paid taxes through the LLC. Then in 2022, you started submitting false invoices through that same LLC. The fact that the fraud was conducted through an LLC doesn’t make it sophisticated—the LLC already existed for legitmate purposes and was operating normally. You just misused it later.
Compare that to this: In early 2023, you decided to commit fraud. You created three seperate LLCs in three different states (Delaware, Wyoming, Nevada). You made LLC #1 the member of LLC #2, and LLC #2 the member of LLC #3. You routed fraudulent funds from your victim into LLC #3, then transferred them to LLC #2, then to LLC #1, then to your personal account.
This multi-layered structure served no legitmate buisness purpose—it was designed solely to obscure the flow of money and make it harder for investigators to trace. That’s sophisticated.
The key diffrence is PURPOSE and TIMING. Did you create the entity for normal buisness reasons before the fraud, or did you create it specifically to facilitate or conceal the fraud? One entity formed before the fraud for legitmate reasons = probably not sophisticated. Multiple entities created during the fraud with no legitmate purpose = definately sophisticated.
But here’s were prosecutors overreach: they’ll call ANY out-of-state LLC “offshore” or “foreign” to make it sound sinister. If your in California and you formed a Delaware LLC, they might describe it as using “offshore corporate entities” in they’re sentencing memo. This is word manipulation, plain and simple.
“Offshore” means foreign jurisdictions—Cayman Islands, Switzerland, British Virgin Islands, Panama. Places were U.S. law enforcement has limited access to banking records and were secrecy laws protect account holders. Delaware is not offshore. Its a U.S. state with normal business regulations and full cooperation with federal investigators. Wyoming is not offshore. Nevada is not offshore.
If the prosecutor is characterizing your Delaware LLC as “offshore,” you need to object with prejudice. That’s a deliberate mischaracterization designed to make routine corporate planning sound like international money laundering. Don’t let them get away with it.
Same thing with the term “corporate shells.” To most people, that phrase implies fake companies with no real operations, created solely for fraud. But prosecutors will use it to describe any LLC, even ones with real buisness activities. If your LLC had actual customers, provided actual services, generated real revenue (in addition to the fraudulent activity), its not a shell—its a functioning buisness that was also misused for fraud. There’s a differance.
Here’s the strategic question you need to ask: How many entities is too many? Based on sentencing data patterns:
– One entity: Enhancement applied in 40% of cases (its a fight, but winnable)
– Two entities: Enhancement applied in 70% of cases (harder, but still arguable)
– Three+ entities: Enhancement applied in 85%+ of cases (very difficult to defeat)
If you only used one entity, your attorney should argue that single-entity structures are routine for small buisnesses and don’t constitute sophisticated means. If you used two, you need a clear explanation for why both were neccessary for legitmate buisness reasons. If you used three or more, you better have an exceptional justification or your probly getting the enhancement.
One more trap: prosecutors will count EVERYTHING. If you formed an LLC for the fraud, but you also have a seperate LLC for your legitmate real estate investments, they’ll count both and say you used “multiple entities.” Object to this. The enhancement only applies to entities USED IN THE FRAUD. Your unrelated legitmate buisness shouldn’t count against you.
Anyways, the bottom line is this: normal buisness structure isn’t sophisticated. But layering, complexity without purpose, and foreign accounts ARE sophisticated. Know which side of the line your on, and fight like hell if the prosecutor is mischaracterizing routine buisness planning as sophisticated fraud.
The Government Is Double-Counting—How to Catch the Non-Stacking Violation
Here’s something that’s gonna make you angry: the prosecutor might be trying to add multiple enhancements when only one is allowed. And if you don’t catch it, the judge might apply them both, illegally adding months or years to you’re sentence.
Under § 2B1.1(b)(10), there are three seperate 2-level enhancements: (A) relocation, (B) mass marketing, and (C) sophisticated means. But here’s the critical part that prosecutors love to ignore: you can only get hit with ONE of these. Not two. Not three. One.
The guideline explicitly states: “Do not apply more than one subsection of subdivisions (A) through (C).” Its right there in black and white. But irregardless of what the rule says, prosecutors routinely argue for sophisticated means enhancement AND relocation enhancement at the same time. They figure if they ask for both, maybe they’ll get both, or at least they’ll get one for sure.
Real talk: this is prosecutorial overreach, and it happens all the time. I’ve seen cases were the PSR recommends +2 for sophisticated means and +2 for relocation, giving the defendant +4 levels total. That’s a direct violation of the guidelines, but if nobody objects, the judge might just go along with it.
So how do you catch this?
Read your PSR carefully. Look at the offense level calculation section. If you see BOTH sophisticated means and relocation (or mass marketing) listed, that’s the violation. Your attorney needs to object immediately—like, within 2-3 days of recieving the PSR, not on day 13.
Here’s what the objection should say: “The PSR erroneously applies both the sophisticated means enhancement under § 2B1.1(b)(10)(C) and the relocation enhancement under § 2B1.1(b)(10)(A). Application Note 9(B) explicitly prohibits applying more than one subsection. The goverment must elect which enhancement to seek, not both.”
Now, here’s were it gets strategic. If the goverment has to choose between sophisticated means and relocation, which one should you WANT them to choose? Generally, you want them to choose the one your MORE likely to defeat. If you’ve got a strong arguement against sophisticated means (based off the “typical fraud” comparison), but you definately relocated your buisness to another state to avoid detection, you’d rather fight sophisticated means. Force them to pick that one.
But if your fraud clearly involved sophisticated methods (offshore accounts, multiple entities, custom software), but the relocation argument is weak (you just moved for personal reasons unrelated to the fraud), then you want them stuck with the sophisticated means enhancement and you’ll concede that one while fighting relocation.
The point is: you get to pick your battle. Don’t let them fight you on two fronts when the rules only allow one.
There’s also a timing issue here. You have 14 days to object to the PSR, but that’s a trap. The probation officer who wrote the PSR starts getting psychologically invested in their recommendations after just a few days. If you wait untill day 12 or 13 to object, they’ve already defended their position to themselves multiple times, they’ve probly discussed it with the prosecutor, and there ego is involved. They don’t wanna be wrong.
But if you object on day 1 or day 2, the probation officer hasn’t locked in yet. There still in “gathering information” mode. They might actually consider your objection and revise the PSR before the addendum. This is way more valuable then fighting it out at the sentencing hearing in front of the judge.
Look, I’m just saying—the goverment isn’t playing fair with this enhancement. They’re gonna argue for everything they can possibly get, regardless of wether its proper under the guidelines. They know most defendants don’t catch the non-stacking violation. They know most defense attorneys are focused on the underlying conviction and haven’t studied the intricacies of § 2B1.1(b)(10). They’re counting on you’re ignorance.
Don’t give them that advantage. Read you’re PSR line by line. If you see multiple enhancements from the same subsection, that’s you’re “gotcha” moment. Object loudly and immediatly. This ain’t gonna fix itself.
At the end of the day, your facing serious consequences, and the goverment doesn’t care about you’re situation irregardless of what they say in court. There trying to maximize your sentence using every tool they have, including tools there not supposed to use. Your job—and your attorney’s job—is to catch them when they overstep.
Plain and simple: if they’re trying to stack enhancements, call them out. Make them choose. And then beat them on the one they pick. That’s how you fight this.
Your Odds on Appeal—Third Circuit Success and Circuit Variations
Let’s say you fought the sophisticated means enhancement at sentencing and lost. The judge applied it. Your devastated. Your attorney is discussing appeal options. You need to know: is this worth appealing, or should you just accept it and start serving your sentance?
Here’s the surprising answer: sophisticated means enhancement actually has a higher reversal rate on appeal then most other sentencing factors. And if your in the Third Circuit (Pennsylvania, New Jersey, Delaware, Virgin Islands), your odds are even better.
In 2024, the Third Circuit reversed 23% of sophisticated means enhancements that were appealed. That’s nearly one in four. Compare that to most sentencing issues, were appellate courts reverse maybe 5-10% of the time. This enhancement is more vulnerable on appeal then most, and there’s a good reason: courts are increasingly skeptical of prosecutorial overreach post-Amendment 587.
The Henriquez case we talked about earlier is a perfect example. The district court applied the enhancement. The defendant appealed. The Third Circuit reversed, holding that the goverment failed to prove the conduct was more sophisticated then typical PPP fraud. That’s a complete win on appeal—the defendant got 2 levels back, which translated to about 8-10 months off there sentance.
More recently, in United States v. Guldi (July 2025), the sophisticated means enhancement came “under fire” again. Defense attorneys are increasingly challenging this enhancement, and courts are listening. The Guldi case is still being litigated, but its getting attention in the defense bar because it represents the kind of aggressive advocacy that actually works.
Now, not all circuits are equally receptive to these appeals.
The Third Circuit has been the most defendant-friendly on this issue, with that 23% reversal rate. The Ninth Circuit (California, Arizona, etc.) is also relatively lenient—they’ve emphasized that conduct must be “especially complex,” not just moderatly complex or somewhat planned.
But if your in the Second Circuit (Southern District of New York, Eastern District of New York), your facing an uphill battle. The Second Circuit is notoriously tough on white-collar defendants, and they tend to defer to district court sentencing decisions. They’ve affirmed sophisticated means enhancements in cases were other circuits might have reversed. It doesn’t mean you can’t win, but your odds are lower—probly more like 10-15% reversal rate based off recent case law.
The Eleventh Circuit (Florida, Georgia, Alabama) falls somewhere in the middle. They’ve reversed some enhancements, particularly when the goverment’s evidence was thin, but there generally deferential to the district court’s factual findings.
So should you appeal? Here’s the calculus:
Appeal if:
- Your in the Third or Ninth Circuit (better odds)
- The enhancement added 10+ months to you’re sentance (worth the fight)
- The district court made a clear factual error (misunderstood what you did)
- The goverment presented little or no comparison to “typical fraud of its kind”
- You have new case law from your circuit that supports your position
Don’t appeal if:
- The enhancement only added 4-6 months (not worth the time and cost)
- Your conduct clearly was sophisticated (offshore accounts, 5+ entities, custom software)
- The district court made detailed findings and comparisons (hard to reverse)
- Your in a circuit with very low reversal rates and no recent favorable precedent
- You’ve already started serving and want certainty rather then more litigation
One more thing: appellate review of sentencing enhancements is for “clear error” only. That’s a high bar. The appellate court won’t just substitute its judgment for the district court’s. They’ll only reverse if the district court made a mistake that’s obvious and significent. So even if you think the enhancement was wrong, the question is wether the judge’s decision was clearly wrong, not just arguably wrong.
That said, the “typical fraud of its kind” standard from Amendment 587 has created new openings for appeal. If the district court applied the enhancement without comparing your conduct to typical fraud in your category, that’s arguably clear error. If the judge just said “using an LLC is sophisticated” without any analysis of wether LLC use is typical for that type of fraud, you’ve got grounds for appeal.
Talk to an appellate specialist, not just your trial attorney. Sentencing appeals require different skills and knowledge. An attorney who’s good at trial might not be the best person to write your appellate brief. Get someone who knows the circuit case law on sophisticated means enhancement specifically and who’s won these appeals before.
What to Do in the First 72 Hours After Getting Your PSR
You just recieved your Pre-Sentence Report. Its 11 PM. You can’t sleep.
You’ve read the offense level calculation section five times, and burried in there is “+2 levels for sophisticated means enhancement under § 2B1.1(b)(10)(C).” You have 14 days to object. What do you do right now?
First, understand this: the 14-day deadline is technicaly correct, but the practical deadline is 2-3 days. Here’s why. The probation officer who wrote your PSR isn’t sitting around waiting to see if you object. There moving on to other cases. There telling themselves that there recommendations are correct. After a few days, they’ve mentally locked in they’re position. By day 4 or 5, there ego is involved—they don’t want to be wrong, so there less likely to revise the PSR even if you make valid points.
But in the first 72 hours, the probation officer is still in “information gathering” mode. If you or your attorney contacts them immediatly with a well-reasoned objection, there much more likely to actually consider it and potentially revise the PSR. This is huge, because if the PSR gets revised before the addendum, you might avoid a fight at the sentencing hearing altogether.
So here’s your action plan for the first 72 hours:
Hour 1-12 (Day 1): Read the PSR completly. Don’t just focus on the bottom-line sentancing range. Read the offense conduct section. Read the offense level calculation. Look for errors in facts, errors in guideline application, and enhancements you can challenge. Make a list.
Hour 12-24 (Day 1): Call your attorney first thing in the morning. Don’t wait untill tommorow. Don’t wait untill next week. Call them immediatly and say: “I recieved my PSR. It recommends sophisticated means enhancement. We need to object within 2-3 days for maximum impact. When can we meet?”
Day 2: Meet with your attorney. Go through the PSR line by line. Discuss every enhancement, every factual assertion, everything. Focus on the sophisticated means enhancement: What specific conduct does the PSR cite as sophisticated? Can you make the “typical fraud of its kind” arguement? Do you have evidence that your methods were routine for this type of fraud?
Day 2-3: Your attorney should start drafting the objection immediatly. Don’t wait untill day 10 or day 13. The objection should be filed by day 3 if possible, no later then day 5. It should be detailed, cite Amendment 587, reference the “typical fraud of its kind” standard, and provide specific examples or case law showing that your conduct wasn’t sophisticated compared to similiar frauds.
Day 3-5: Your attorney should also contact the probation officer directly (by phone or email) to discuss the objection. This informal contact can be more effective then just filing a written objection. The probation officer might agree to revise the PSR if they understand your position and realize there recommendation was based on incomplete information or a misunderstanding.
What documents should you gather to support your objection? It depends on the specific facts, but generally:
- Evidence of legitmate buisness purpose for any entities you formed (articles of incorporation filed before the fraud started, buisness licenses, tax returns showing real operations)
- Evidence of standard software use (QuickBooks subscription receipts, proof you didn’t write custom code)
- Case law from your circuit showing similiar conduct wasn’t deemed sophisticated
- News articles or DOJ press releases about other cases in your fraud category, showing that your methods were typical
One critical point: don’t try and argue that you didn’t commit fraud or that your innocent. The PSR objection isn’t the place for that—you already pled guilty or were convicted. The objection is about the CHARACTERIZATION of your conduct. You can admit the fraud while arguing it wasn’t sophisticated.
Example: “The defendant does not dispute that he submitted false invoices to obtain payment for services not rendered. However, the use of invoices created in Microsoft Word is not ‘especially complex or intricate’ compared to typical false billing fraud. See Henriquez. The goverment has provided no evidence that the defendant’s methods exceeded what is typical for this type of fraud.”
Another strategic consideration: prioritize your objections. Don’t fight everything. If the PSR gets 5 things wrong, pick the 2-3 most impactful ones and fight those hard. If you object to every single thing, you’ll lose credibility and the judge will think your just being difficult. But if you pick your battles carefully and make strong arguments on a few key points, you’ll be more persuasive.
And one more thing: don’t assume your trial attorney knows all of this. Some excellent trial attorneys don’t specialize in sentencing. If your attorney seems confused about Amendment 587 or hasn’t heard of the “typical fraud of its kind” standard, you might need to bring in a sentencing specialist for this phase. Its not an insult to your attorney—its recognizing that sentencing is a different skill set.
Bottom line: you have 14 days to object, but you need to act in 2-3 days for maximum impact. Right now. Today. Not next week. Because this matters. Seriously.
Call a Federal Sentencing Attorney Who Knows How to Fight This
Your facing a sophisticated means enhancement that could add 14 months or more to you’re federal prison sentence. You need an attorney who understands Amendment 587, knows the “typical fraud of its kind” comparison, and has actually fought these enhancements successfully. If you call an attorney and mention Amendment 587 and they don’t immediatly know what your talking about, call someone else.
Ask specific questions: Have you challenged sophisticated means enhancements before? What were the outcomes? Do you know the reversal rates in our circuit? Can you explain the non-stacking rule under § 2B1.1(b)(10)? If there answers are vague or generic, keep looking.
Time is critical. You have 14 days to object to your PSR—but realistically, you need to file objections within 2-3 days to have maximum impact. Every day you wait, the probation officer becomes more invested in there recommendation. The judge will see your PSR soon. This window closes fast.
Don’t wait. Call now. Your life—and years of it—depends on getting this right. Irregardless of what you’ve been told, this enhancement IS beatable in the right cases with the right arguments. But you gotta fight it. Right now. We’re here. 24/7.
Your the one who’s facing this. Your the one who’s gonna serve the time. Make sure you’ve got someone in your corner who actually knows how to win this fight. Because wether you fight or accept this enhancement effects everything about you’re sentance and you’re future.