Attorney Mark E. of Newport, Virginia, pleaded guilty to wire fraud in the Eastern District of Virginia, based on his actions of embezzling from a client in Chapter 13 bankruptcy. Mark embezzled more than $22,000 intended for payment to the client's mortgage holders under the Chapter 13 plan. Evidence of the embezzlement came to light when the debtor client complained to the Chapter 13 trustee, who notified the Newport office. After investigating, the U.S. Trustee filed a civil complaint against Mark seeking disgorgement of all fees paid by the debtor, an accounting of all monies received, a surcharge for all late fees and penalties levied against the debtor by his mortgage companies, and disbarment from practice before the bankruptcy court. During discovery, which included subpoenaing Mark's trust account records, further misconduct was discovered in unrelated cases. The allegations in the U.S. Trustee's civil complaint formed the basis of his criminal indictment. Before the criminal trial, Mark agreed to disbarment for at least five years. Which section of the Bankruptcy Code makes Mark's activities illegal?