In the United States Court of Appeals FOR THE SECOND CIRCUIT

AUGUST TERM 2023 No. 22-533

UNITED STATES OF AMERICA, Appellee,

v.

LAURIE WEINLEIN, Defendant-Appellant.

On Appeal from the United States District Court for the Northern District of New York

SUBMITTED: NOVEMBER 30, 2023 DECIDED: JULY 25, 2024

Before: LYNCH, PARK, and MENASHI, Circuit Judges.

Defendant-Appellant Laurie Weinlein was convicted of bank fraud and embezzlement from an employee benefit plan and sentenced to sixty-three months in prison, a five-year term of supervised release, and over $2 million in restitution payments. At the time Weinlein committed her crimes, the Victim and Witness Protection Act (“VWPA”) provided that a criminal restitution obligation terminated twenty years from the date of judgment. In 1996, Congress enacted the Mandatory Victims