Moneygram records of wire transfers admissible as business records

US v. Keck, -- F.3d --, 2011 WL 2600581 (10th Cir. 7/1/11) - affirmance of convictions and sentence on multiple drug and money-laundering conspiracy counts. There was sufficient evidence to support the convictions. Moneygram spreadsheets which reflected company records of wire transfers were properly admitted because, like mobile phone records, they contained data created for the company's own purposes and not to prove a fact at trial and thus were not testimonial. Adjustments to Keck's drug conspiracy offense level, based on conduct that related to the money-laundering conviction, were proper. Any error the district court made in applying the GLs did not affect the advisory sentence or the court's decision to impose a life sentence.