Glossary term
Structuring (Smurfing)
Subject: Financial Crime, Money Laundering, Typologies and Asset Recovery
Also known as: Smurfing, Structuring
Structuring, also called smurfing, is splitting a large amount of cash into smaller deposits or transfers, often across accounts or people, to stay below reporting thresholds and avoid attention.
Explanation
Many countries require banks to report cash above a set amount. Structuring tries to slip under that line. The person may make several deposits just below the limit, spread them over days, branches or accounts, or use helpers (the "smurfs") to do it. Each deposit looks ordinary; the pattern gives it away, such as repeated amounts just under a threshold, or many small deposits followed by one large transfer. In some jurisdictions structuring is a crime in its own right, even if the money is legal, because the aim is to evade reporting. Monitoring rules look for it by adding up activity across accounts and time. Teams that watch only single deposits miss it entirely, so alert rules are tuned to totals over time.
Example
Where the reporting threshold is 10,000, a customer deposits 9,500 in cash at three branches on the same day and another 9,000 at an ATM the next morning. The bank's monitoring system adds the deposits together and flags the pattern, and the compliance team files a suspicious activity report.
Not to be confused with
- Layering
- Layering moves money through many transactions to hide its origin. Structuring happens at the start, when cash enters the system.