Structuring / smurfing

Breaking up a large sum of money into smaller transactions specifically to stay under the amount that triggers a bank's reporting requirement.

For example, instead of depositing a large amount of cash at once, someone might deposit smaller amounts over several days so that no single deposit crosses the reporting line.

Deliberately dividing transactions to stay under a mandatory reporting threshold, which in the US is the $10,000 threshold that triggers a Currency Transaction Report under the Bank Secrecy Act, either through repeated deposits by one person or, in the smurfing variant, coordinated deposits by multiple people across different accounts or branches.

The two names describe related behavior:

• Structuring is the act of breaking up transactions to avoid a report, usually by one person.
• Smurfing is the version in which many people, called smurfs, each make small deposits for a larger scheme.

A structuring pattern typically looks like this:

1. Someone has a large amount of cash to place into the financial system.
2. They split it into amounts just under the reporting threshold.
3. They deposit the pieces over several days, at several branches, or through several accounts.
4. The money now sits in the system without triggering an automatic report.

Banks watch for warning signs:

• Repeated deposits just under the threshold, especially in a short period.
• Many accounts or branches used for similar amounts.
• Unrelated people depositing similar amounts into one account.

Reporting thresholds differ by country, so the amounts and forms vary even where the idea is similar.

Structuring sits next to terms that are easy to mix up:

• Bank Secrecy Act is the US law behind the reporting requirement.
• Suspicious activity report is the filing a bank makes when it spots a pattern such as structuring.
• Money mule is an account used to move illicit money, and smurfing often relies on them.

For more, see Understanding Structuring in Money Laundering and What is Smurfing in Money Laundering?.