JUSTICE O'MALLEY delivered the opinion of the court:

Defendant, Rodney Fields, appeals from his conviction of twocounts of money laundering (720 ILCS 5/29B--1 (West 2000)),following a bench trial before the circuit court of Du Page County. Defendant contends that the trial court made prejudiciallyerroneous evidentiary rulings during the trial, that the indictmentinsufficiently apprised him of the illegal conduct with which hewas charged, and that the evidence presented by the State wasinsufficient to prove him guilty beyond a reasonable doubt of thecharged offenses. We agree that the indictment was fatallydeficient, and we reverse.

This matter arose from defendant's purchase of two cars fromLaurel Motors in Westmont. Defendant was indicted for moneylaundering and, on November 13, 2000, he moved to dismiss theindictment, arguing that the two counts were pleaded generally andwithout specificity. The trial court denied defendant's motion butordered the State to provide a bill of particulars specifying thenature of the criminally derived property and its source. OnNovember 28, 2000, the State filed its bill of particulars, statingthat count I alleged money laundering in connection with the saleand financing of a 1999 Mercedes automobile and that count IIalleged money laundering in connection with the sale and financingof a 2000 Mercedes automobile. The State noted that the nature ofthe criminally derived property was defined by statute and outlinedin the discovery tendered to defendant. The State concluded thatit was not aware of the source of any criminally derived funds.

Defendant again moved to dismiss the indictment, arguing thatthe statute so broadly defined criminally derived property that hecould not prepare a defense. Defendant also argued that theindictment was still so unspecific as to be defective. The Statereplied that it had complied with all applicable discovery rules. The trial court denied defendant's second motion to dismiss. Thereafter, the matter proceeded to a bench trial.

At trial, the evidence showed that, in January 1999, defendantentered Laurel Motors in Westmont, Illinois, to purchase a MercedesS430 automobile. At that time, defendant had not filed a taxreturn since 1996. The model defendant was seeking was backordered, so defendant would have had to wait about six months toobtain it. Instead, Laurel Motors salesman Joe Smalzer offereddefendant a less expensive model, a CLK 430. On about March 20,1999, defendant agreed to purchase the CLK 430 and filled out anapplication for credit with the Mercedes Credit Corporation in hisown name. Defendant was accompanied by Edwin Jones. Jones alsofilled out an application for the financing necessary to purchasethe CLK 430. Some of the documents were signed by defendant andsome were signed by Jones. Smalzer could not remember how heobtained all of the documents and was unaware of who signed whatdocuments. Smalzer was also unaware to whom the car was delivered,but he testified that he saw defendant drive it into the dealershipfor servicing.

As part of the information collected by Laurel Motors for thefinancing, defendant provided a W-2 form listing Jones as anemployee of Supreme Life Entertainment. The W-2 form provided bydefendant showed that Jones was earning an annual salary of$98,000. Jones testified that he had never been employed bySupreme Life Entertainment. The State introduced records from theDepartment of Revenue showing that Supreme Life Entertainment neverpaid taxes. Detective William Murphy visited the two addressesprovided on the W-2 form for Supreme Life Entertainment. At thoseaddresses, he found a vacant store front and a boarded-up home. Detective Murphy did not investigate further to determine theleasing history, if any, of the two properties.

Jones testified that, in the purchase of the CLK 430,defendant provided all of the money for the down payment. Jonesdid nothing but fill out some paperwork and sign documents whentold to sign.

In June 1999, the car defendant had originally wished topurchase, a Mercedes S430, became available, and Laurel Motorscontacted defendant. Defendant indicated that he wanted to get thecar, but would again have Jones assist him with the paperwork. Mercedes Credit initially rejected financing for the secondpurchase, as it was so close in time to the first purchase. Smalzer explained to Mercedes Credit that defendant originallywanted the S430, which was unavailable in March, and MercedesCredit approved the financing. The information that had beensubmitted for the financing on the CLK 430 was copied and submittedagain. The total down payment of $9,500 for the S430 again wasprovided entirely by defendant even though it was logged as havingbeen received from Jones. Defendant conducted and completed thenegotiations for the purchase of the S430 before the appearance ofJones, who once again signed documents when told to do so.

Jones testified under a grant of use immunity. He testifiedthat, in March 1999, he accompanied defendant to Laurel Motors tocosign for a loan on a car. Once there, he learned that, even witha cosigner, defendant would be unable to purchase the car due todefendant's poor credit. To avoid either a very large down paymentor an unfavorably high interest rate, Jones testified that hesigned as the purchaser, even though defendant did not ask him toact as the purchaser. He further testified that he filled out thecredit application at the dealership, listing his employer asSupreme Life Entertainment and his annual salary as $98,000,because he did not want anyone calling his actual employer. Jonesdenied that defendant asked him to list Supreme Life Entertainmentas his employer. Jones testified that a W-2 for his purportedemployment at Supreme Life Entertainment was produced but that hedid not know where the W-2 came from.

Jones admitted that he had never worked for Supreme LifeEntertainment. He did not know where the down payment on the firstcar came from but witnessed defendant make the down payment on thesecond car. Jones testified that he did not make any of themonthly payments on the cars and did not know how they were made.

Jones testified that both he and defendant drove the firstcar. With respect to the second car, Jones testified thatdefendant picked it up when it was ready and was the primarydriver. Jones testified that the second car was put in his namedue to defendant's poor credit.

A number of Jones's statements were impeached by a writtenstatement Jones had provided to police. The statement was redactedand admitted as substantive evidence pursuant to section 115--10.1of the Code of Criminal Procedure of 1963 (Code) (725 ILCS 5/115--10.1 (West 2000)). The court admitted the following four portionsof Jones's written statement given to the Wheaton police:

1. "In April 1999 [defendant] ask [sic] if I could co-sign for a 1999 CLK 430 Mercedes Benz. [Defendant] changed his[sic] and then ask [sic] if I could finance the vehicle for him."

2. "[Defendant] provided Schmalzer [sic] with the W-2 form for Supreme Life Entertainment. [Defendant] had me employedas vice president earning $98,000 yearly."

3. "[Defendant] ask [sic] me to put this vehicle in my name because he did not have a legitimate source of income."

4. "[Defendant] told [sic] did not want this vehicle in his name because he has no legitimate source of income."

Katrina Mack next testified, also under a grant of useimmunity. She testified that she was defendant's girlfriend. Shetestified that, in December 1999, she had helped defendant purchasea Cadillac Escalade. Mack testified that she negotiated thepurchase of the vehicle. She was impeached, however, by herwritten statement to police in which she stated that she had signedfor the Escalade after defendant had negotiated the deal. Mackthen testified that the police told her what to say.

Continuing, Mack testified that she made both the down paymentand the first payment for the Escalade from her own funds, afterwhich the car was repossessed. Mack was again impeached by herwritten statement, which related that defendant made both the downpayment and the first monthly payment. Mack again stated that theWheaton police had told her what to say.

When asked how defendant made his money, Mack testified thatshe did not know. She was shown her written statement in which shestated, "[A]ll of [defendant's] money comes from dealing drugs." Defendant's objection to that statement as a conclusion wasoverruled.

At that point, the State moved to admit the entirety of Mack'swritten statement as substantive evidence pursuant to section 115--10.1 of the Code. After hearing argument, the trial court took thematter under advisement and concluded the proceedings for the day. When the proceedings resumed the next day, the trial court admittedthe written statement in its entirety as substantive evidence. Thetrial court noted that portions of the written statement alsoconstituted admissions by defendant and rejected defendant'sargument that they instead constituted double hearsay.

Mack's written statement related:

"Dec. 19, 1999[,] I purchase [sic] a Cadillac Escaladefrom Foley-Rice in Oak Park [sic] the vehicle was put in myname for [defendant]. I know [defendant] to be a drug dealerand the vehicle was put in my name because [defendant] has nojob and no way to show payments of the vehicle other than drugmoney. [Defendant] made the down payment of [$]3,000 and makesthe insurance pymts. of [$]184.00. The bill is sent to myhouse and [defendant] picks them up and gets a money order for$683.509 and $184.00. I've been dating [defendant] for 8months and he hasn't had a job since. All of [defendant's]money comes from dealing drugs. We had numerous conversation[sic] of where his money come [sic] from and have hear he[sic] on his cell phone speaking of this. I know of about 4people that sell drugs for him. [Defendant] spends about[$]20-40 thousands on drugs a month. I signed for the truckafter [defendant] negotiated the deal with Joe Ott. I wastrying to do a favor for [defendant]. I have no claim to thetruck."

When Mack was cross-examined, she testified that she had neverseen defendant deal drugs or sell drugs. She also denied that sheheard defendant talk about selling drugs.

The State called Officer Murphy, who testified about thecircumstances of the taking of Mack's written statement. He deniedthat he had told Mack what to say.

Detective William Cooley of the Wheaton police departmenttestified next. He testified that, on February 10, 2000, he triedto arrest defendant. He first observed defendant driving a blackCadillac Escalade in Maywood. Detective Cooley was driving a semi-unmarked black Crown Victoria at that time. Defendant entered theI-290 expressway and proceeded eastbound while Detective Cooleyfollowed him. Detective Cooley testified that defendant remainedin the right-hand lane until he eventually exited and stopped hiscar in front of the 15th District Chicago police station, at whichtime defendant was taken into custody.

Defendant was then transported to the Wheaton policedepartment and questioned. Defendant was given Miranda warningsand agreed to give a verbal statement but refused to put anythingin writing, including a signed Miranda waiver. Detective Cooleytestified that defendant admitted that he used to sell cocaine withDerrick Jones, Edwin Jones's brother. According to DetectiveCooley, defendant stated that he had gone to Laurel Motors topurchase a car, and that he negotiated the deal and then askedJones to come in to sign the papers. He used Jones because Joneshad a job.

With regard to the second vehicle, the S430, defendant againused Jones to help him. Defendant admitted making all of thepayments on the cars. Detective Cooley testified that defendantstated that, when he received a telephone call from Joe Smalzer atLaurel Motors advising him that the police had been there askingabout his vehicle, defendant dumped his cell phone in order tofrustrate the ability of the police to track him. Detective Cooleytestified that, with regard to the Escalade, defendant told himthat Mack had purchased the vehicle for him.

Defendant told police that he was a record producer and hadmade $8,000 with Supreme Life Entertainment. He admitted that hewas a small-time drug dealer and had sold about a quarter-kilogramof cocaine during the period of January to April 1999. Defendantbecame belligerent over his arrest, telling the detectives thatarresting him in public could get him killed because people wouldknow that "he's hot." Detective Cooley also testified thatdefendant told him that he had purchased a kilogram of cocaine onseveral other occasions and that sometimes the cocaine was frontedto him, meaning that he did not have to pay for it in advance. Detective Cooley testified that defendant did not give him anyspecific detail on these other purchases.

On cross-examination, Detective Cooley testified that, whendefendant stopped in front of the 15th District Chicago policestation, he was ordered out of the car at gunpoint. Defendant toldpolice that he had driven to the Chicago police station because hedid not know that it was the police who were following him and hethought that they were people who were going to kill him. Detective Cooley explained that his vehicle had no exterior policemarkings. Detective Cooley testified that defendant's car wassearched and no contraband was discovered. He testified that theinterview with defendant lasted three hours. Defendant denied thathe had any ownership rights to the Escalade and denied making anypayments for it.

The State offered into evidence records regarding the purchaseof a Ford Expedition and the Escalade. The State also offered intoevidence redacted portions of Jones's written statement and Mack'swritten statement. Following the admission of these documents, theState rested. The trial court denied defendant's motion for adirected finding.

Defendant did not testify. Defendant offered into evidencethe articles of the limited liability company, Supreme LifeEntertainment. Defendant then rested.

The trial court found defendant guilty of both counts. Thetrial court noted that this case differed from most moneylaundering investigations because they usually arise out of othercriminal offenses, but in this case, there was no specificunderlying criminal activity to form the basis of any particularcharges. The trial court relied on Mack's written statement infinding that defendant had no job and that his income was derivedfrom selling drugs. The trial court also found it significant thatSupreme Life Entertainment had not been incorporated or filed anytax returns. Defendant's posttrial motion for a new trial wasdenied, and defendant was sentenced to a three-year term ofimprisonment. Defendant timely appeals.

On appeal, defendant contends that Mack's written statementand the portions of Jones's written statement were erroneouslyadmitted as substantive evidence. Defendant also argues that theindictment failed to sufficiently specify the nature and elementsof the offense and was, therefore, fatally deficient. Last,defendant argues that the evidence presented at trial wasinsufficient to prove him guilty beyond a reasonable doubt.

Because we find the indictment issue to be dispositive, weconsider it first. Defendant argues that the indictment wasinsufficient and too vague to allow him to prepare a defense inthis matter. The State indicted defendant on two counts of moneylaundering. The first count alleged, in pertinent part:

"[O]n or about the 16th day of April, 1999, at and withinDuPage County, Illinois, [defendant] committed the offense ofMoney Laundering in that said defendant knowingly engaged ina financial transaction in criminally derived property with avalue exceeding $10,000.00 and knew that the financialtransaction was designed in whole or in part to conceal thesource of the criminally derived property in violation of 720ILCS 5/29B--1 [(West 2000)]."

The second count of the indictment alleged, in pertinent part:

"[O]n or about the 16th day of August, 1999, at and withinDuPage County, Illinois, [defendant] committed the offense ofMoney Laundering in that said defendant knowingly engaged ina financial transaction in criminally derived property with avalue exceeding $10,000.00 and knew that the financialtransaction was designed in whole or in part to conceal thesource of the criminally derived property in violation of 720ILCS 5/29B--1 [(West 2000)]."

Defendant filed two motions to dismiss the indictment in the trialcourt, both of which were denied. On appeal, defendant argues thatthe indictment lacked the necessary detail to allow him toadequately prepare for trial. We agree.

When a defendant challenges an indictment before trial, thecourt must review it to determine whether the indictment compliedwith section 111--3 of the Code (725 ILCS 5/111--3 (West 2000)). People v. Komes, 319 Ill. App. 3d 830, 833 (2001). Section 111--3(a) requires the charge to state, in writing, the name of theoffense, to cite the statutory provision alleged to have beenviolated, and to state the name of the accused, the date of theoffense, the county in which the offense occurred, and the natureand elements of the offense. 725 ILCS 5/111--3(a) (West 2000);Komes, 319 Ill. App. 3d at 833.

Here, the indictment named the offense and the statutorysection that was violated. It included the dates of theoccurrences and the county in which the offenses occurred, and itnamed the defendant. Last, it recited the elements of the offenseby mirroring the statutory language.

Defendant argues that the recitation of the terms of thestatute was insufficient because the statute defines the offense in only general terms. In support, defendant cites People v.Gerdes, 173 Ill. App. 3d 1024 (1988), People v. Yarbrough, 162 Ill.App. 3d 748 (1987), and People v. Lyda, 27 Ill. App. 3d 906 (1975). Defendant argues that, when a statute encompasses a wide variety ofconduct, the indictment must define the nature and elements of theoffense in terms that are more specific than the broad and generallanguage of the statute. We agree.

In Gerdes, the defendant was charged with obstructing justiceby furnishing false information. The court held that a charge ofobstructing justice required more specificity than merely thestatutory language. Gerdes, 173 Ill. App. 3d at 1029-30. Theindictment referred to two statements given by the defendant butdid not indicate which was the basis of the obstructing justicecharge. The court held that the indictment lacked the specificityand particularity required to adequately inform the defendant ofthe charges against him. Gerdes, 173 Ill. App. 3d at 1030.

In Yarbrough, the indictment for communication with a jurorwas held to be insufficient where the content of the communicationwas not included. Yarbrough, 162 Ill. App. 3d at 750-51. In Lyda,the indictment for obstruction of justice by destroying physicalevidence was insufficient where it did not describe the physicalevidence. Lyda, 27 Ill. App. 3d at 912. We find these cases to besufficiently similar to the instant case as to support defendant'sargument that the indictment should have included more specificityregarding the elements of the offense.

The money laundering statute describes the prohibited conductin only the most general terms. A person commits the offense ofmoney laundering:

"when he knowingly engages or attempts to engage in afinancial transaction in criminally derived property witheither the intent to promote the carrying on of the unlawfulactivity from which the criminally derived property wasobtained or where he knows or reasonably should know that thefinancial transaction is designed in whole or in part toconceal or disguise the nature, the location, the source, theownership or the control of the criminally derived property." 720 ILCS 5/29B--1(a) (West 2000).

For example, the term "criminally derived property" is defined as"any property constituting or derived from proceeds obtained,directly or indirectly, pursuant to a violation of the CriminalCode of 1961, the Illinois Controlled Substances Act or theCannabis Control Act." 720 ILCS 5/29B--1(b)(4) (West 2000). Thus,anything obtained from a violation of the criminal and drugstatutes can constitute the criminally derived property at issue inthe indictment for money laundering. The State's failure tospecify the "criminally derived property" at issue left defendantguessing as to whether he allegedly obtained the "criminallyderived property" in violation of the drug statutes, a theft, orsome other action that violated the criminal statutes.

Similarly, "financial transaction" is defined as:

"a purchase, sale, loan, pledge, gift, transfer, deliveryor other disposition utilizing criminally derived property,and with respect to financial institutions, includes adeposit, withdrawal, transfer between accounts, exchange ofcurrency, loan, extension of credit, purchase or sale of anystock, bond, certificate of deposit or other monetaryinstrument or any other payment, transfer or delivery by,through, or to a financial institution." 720 ILCS 5/29B--1(b)(1) (West 2000).

In this case, the indictment did not indicate whether defendant's"financial transaction" was the securing of a loan to pay for thecars, the payment of the down payment, the payment of the monthlyinstallments, or a combination of any or all of those activities. As a result, defendant here, like the defendant in Gerdes who wasfaced with two possible bases for the offense of obstructingjustice, was left to guess at which action was serving as the basisfor money laundering charges against him. Thus, the two keyelements of the offense, the "criminally derived property" and the"financial transaction," were defined in broad and conclusorylanguage and did not apprise defendant of the prohibited conduct atissue in this case.

We note that the State's response to defendant's argumentsfails completely to consider Gerdes, Lyda, or Yarbrough. Each ofthose cases held that broad statutory language requires theindictment to be pleaded with more particularity than is present inthe statutory language. Because the State entirely fails tograpple with this issue, we find its response inadequate. Insteadof dealing with the meritorious issue defendant raises, the Statesidesteps the issue and claims that where the indictment complieswith section 111--3 of the Code, then a defendant can prevail onlyby showing he was deprived of due process. In light of thespecificity and particularity requirements imposed by Gerdes, Lyda,and Yarbrough, we must disagree with the State. We also note that,in any event, because the State here failed to describesufficiently the necessary elements and nature of the offensesalleged, the indictments do not comply with section 111--3 of theCode.

In addition, the State seems to suggest that the bill ofparticulars it provided should have cured any defects in theindictment. Where an indictment fails to allege adequately thenature and elements of the offense, that is a fundamental defectthat renders the indictment void and it cannot be amended as in thecase of a simple formal defect. People v. Alvarado, 301 Ill. App.3d 1017, 1023 (1998). We note that, while a bill of particularsmay supplement a sufficient charge and thereby assist a defendantin preparing his defense, a bill of particulars cannot be used tocure a void charge. People v. Aud, 52 Ill. 2d 368, 370 (1972);People v. Scott, 285 Ill. App. 3d 95, 99 (1996); Yarbrough, 162Ill. App. 3d at 751. Here, the State failed to charge adequatelythe nature and elements of money laundering where the charge onlymirrored the statutory language. This was a fundamental defect inthe indictment and rendered it void. The bill of particulars didnot cure the defects in the indictment.

As a final comment, we note that the State, in arguing thatdefendant could not show a due process violation, cites a number ofcases in which the underlying criminal activity, such as drugtrafficking, was proved at trial. For example, the State quotes atlength United States v. Webster, 960 F.2d 1301, 1308 (5th Cir.1992), for the proposition that it need not prove precisely thesource of the criminally derived property. While Webster may standfor the proposition that evidence of a significant differentialbetween legitimate income and cash outflow may support a convictionof money laundering, the government also presented evidence attrial of actual drug sales. Thus the source of all of thecriminally derived property in Webster may not have been fullyidentified, the government nevertheless concretely attributed someof the money as coming from drug transactions. Webster, therefore,was a significantly stronger case than this one, where the Statedid not present any evidence of specific drug transactions ondefendant's part.

As we have decided that the indictment was fatally defective,we need not address defendant's other contentions. For theforegoing reasons, therefore, the judgment of the circuit court ofDu Page County is reversed.

Reversed.

CALLUM and GILLERAN JOHNSON, JJ., concur.