AML & Compliance

What is structuring?

The illegal practice of breaking up large financial transactions into multiple smaller ones to avoid triggering regulatory reporting thresholds—specifically the $10,000 CTR filing requirement in the United States. Also known as “smurfing,” structuring is a federal crime regardless of whether the underlying funds are legitimate, and it is a key typology monitored by AML programs.

How it works

Example: An individual makes cash deposits of $9,500 at four different bank branches within three days. The bank’s AML system aggregates the transactions, identifies the structuring pattern, and generates a SAR.