In an unpublished decision, the Ninth Circuit noted that a dismissed indictment for conspiracy to commit money laundery, without more, is not sufficient to demonstrate that an applicant engaged in money laundering.  

"Even assuming that participation in a conspiracy to commit money laundering constitutes 'reason to believe' that the participant in fact engaged in money laundering, the evidence in this case falls short.  A dismissed indictment, without more, does not constitute “reason to believe” that the defendant committed the crime charged." 

This language may provide valuable argumentation for lawyers dealing with "reason to believe" standards, such as those related to drug trafficking.

The full text of Obeid v. Lynch can be found here: