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Money laundering: What are structuring and smurfing?

On Behalf of | Oct 23, 2023 | Criminal Defense

Most people are familiar with the term “money laundering.” Fewer have heard the terms “structuring” and “smurfing.” 

First, it’s important to understand the federal Bank Secrecy Act (BSA). It requires financial institutions to report large cash transactions. The BSA is intended to help prevent financial crimes, such as money laundering, that often involve large transfers of cash. Often, fraud, extortion and narcotics crimes are behind money laundering. 

Both structuring and smurfing involve separating large cash transactions into smaller ones to avoid triggering a report to federal authorities. However, there are differences.


This is when someone – usually an individual — intentionally makes cash deposits of under the minimum of $10,000 per day that requires reporting via a Currency Transaction Report (CTR). These reports are automated, so a bank employee can’t “forget” to file one. 

Structuring is a violation of Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) regulations. If someone is suspected of structuring, they’re likely to face close scrutiny by authorities since it’s often a sign of other illegal activity.


Smurfing involves the same activity of intentionally breaking large deposits of cash into smaller ones to avoid triggering reporting. The main difference is that it typically involves multiple people making transactions at various financial institutions. 

The people who make these transactions are sometimes called “smurfs.” The accounts they’re depositing the money to may seem completely unrelated even though they’re all part of the same money laundering enterprise. Typically, smurfing involves a larger, more sophisticated operation.

Attempts to avoid large deposits can often be detected – and reported

Of course, law enforcement and financial institutions long ago caught on to the fact that people were making multiple small deposits or deposits just under the $10,000 limit to avoid the CTR reporting. That’s why banks can file a Suspicious Activity Report (SAR) when employees believe – or the system suggests based on activity – that someone is trying to avoid a CTR.

As you might imagine, it can be easy to unwittingly be used as a “smurf” to make one or more of these deposits. If you work for a store or other business, you might be told you’re simply making a daily deposit for your employer. It’s also possible that a legitimate business that deals in cash could arouse suspicion and investigation.

Even if you’re completely innocent of intentional wrongdoing, you could find yourself facing serious criminal charges. It’s crucial to get experienced legal guidance as soon as possible to protect your rights and present your case.

Contact the Quinn law firm on 814-833-2222 to discuss your options. 

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