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Structuring (Smurfing)

Definition

A placement-stage technique in which large cash amounts are broken into multiple smaller deposits or transactions, each deliberately kept below the threshold that triggers a cash transaction report. In the United States the reporting threshold is $10,000; in the EU it is EUR 10,000. Structuring itself is a criminal offence in most jurisdictions, independent of the underlying predicate crime.

Related terms

Beneficial owner
The natural person who ultimately owns or controls a legal entity or arrangement, as distinct from the nominee or registered owner. Anti-money-laundering...
Integration
The third stage, in which laundered funds re-enter the legitimate economy as apparently clean wealth. Common integration mechanisms include real estate purchases,...
Layering
The second stage, designed to sever the audit trail between the illicit source and the funds. Layering typically involves a rapid series...
Placement
The first stage of money laundering, in which illicit cash is introduced into the financial system. Methods include cash deposits, currency exchange,...
Trade-based money laundering (TBML)
A typology that uses international trade transactions to transfer value across borders. Mechanisms include over-invoicing or under-invoicing goods, falsifying quantities or descriptions,...

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