app/plugins/knowledge_base/typologies/aml/structuring.md

Money Laundering Typology: Structuring (Smurfing)

Definition

Structuring involves breaking down large cash transactions into smaller amounts to avoid triggering mandatory reporting thresholds (e.g., the $10,000 CTR limit in the US).

Indicators & Red Flags

• Just Below Threshold: Multiple deposits of $9,000 - $9,900.
• Multiple Locations: Deposits made at different branches or ATMs on the same day.
• Frequent Cash: Patterns of cash deposits that deviate from normal business practice.
• Reaction to Questions: Customer reduces amount after being asked for ID.

Detection Logic

• Volume Rule: Count(Transactions between $9k-$10k) > 2 in 7 days.
• Aggregated rule: Sum(Cash Transactions) > $10k but individual Max(Txn) < $10k.

Response

• Immediate SAR filing (Structuring is a crime in itself, regardless of source of funds).
• Do NOT tip off the customer.