Structuring
Designing transactions specifically to fall below regulatory reporting or due-diligence thresholds - a criminal offence in its own right under most major regimes.
Definition
Structuring is the deliberate design of one or more transactions to remain below a reporting threshold (cash transaction reports, currency import declarations, due-diligence triggers) or to avoid being aggregated. It overlaps heavily with smurfing but is the regulatory term of art - and a stand-alone offence under the US Bank Secrecy Act and most EU national laws.
Classic patterns
- Cash deposits of $9,500 made repeatedly to avoid the $10,000 CTR trigger.
- Wire transfers split into 4 × €12,500 to avoid an internal "€50k+" manual review.
- Crypto withdrawals broken into many transactions under a VASP's KYC tier.
- Multiple invoices issued just below an internal procurement-approval threshold.
Regulatory anchor
US 31 USC §5324 makes structuring a federal crime regardless of whether the underlying funds are illicit. The EU AMLR removes the "single-transaction" defence by codifying aggregation rules: linked transactions must be summed when the obligated entity has reasonable grounds to suspect they are connected.