Structuring

Structuring introduces illicit funds into the financial system in sub-threshold increments, explicitly avoiding mandatory reporting triggers and reducing initial detection risks at the placement stage.

Structuring also supports layering by breaking down large sums into multiple smaller transactions executed across various accounts or channels. This explicitly obscures the origin and trail of illicit funds through distributed activities.

Criminals employ structuring during integration to systematically introduce laundered funds into legitimate commerce or investments in sub-threshold increments, ensuring seamless assimilation while minimizing red flags.

Structuring exploits threshold-based controls inherent in deposit, remittance, and related financial products. By methodically splitting larger sums into sub-threshold transactions, criminals leverage product-level alerts—such as currency transaction reporting triggers—to evade detection and circumvent automatic monitoring tools. This technique depends on the built-in threshold mechanisms of each product or service, ensuring every deposit or transfer remains nominally compliant and undetectable when viewed individually.

Stealth addresses exploit digital channels that obscure the movement of funds, reducing transparency and complicating transaction monitoring efforts.

• Captures transaction details, card identifiers, and usage patterns for prepaid or stored-value cards.
• Detects repeated small-value loads or withdrawals and flags cumulative amounts exceeding threshold limits.
• Aids in uncovering structuring via multiple prepaid cards or stored-value accounts used to evade reporting triggers.

• Provides timestamps, transaction amounts, account identifiers, and deposit/withdrawal records for all financial movements.
• Enables detection of multiple sub-threshold transactions conducted in quick succession or across various channels.
• Facilitates aggregation analysis to identify total funds moved by a single user, flagging suspicious structuring patterns designed to circumvent reporting thresholds.

• Lists licensed money service businesses and associated registrations, including ownership and operational scopes.
• Identifies whether the same individual or entity is using multiple MSBs for repeated sub-threshold transactions that collectively exceed reportable limits.
• Aids in determining if reported MSB usage aligns with the customer’s declared profile and accounts, revealing potential structuring activity.

• Contains verified customer identification data, beneficial ownership information, account relationships, and risk profiles.
• Allows comparison of declared customer details with observed multiple account usage below reporting thresholds.
• Helps identify whether the same individual is using multiple accounts or aliases to evade detection of aggregated deposit amounts.

• Records on-chain transaction data, including wallet addresses, timestamps, transaction amounts, and receiving parties, across various digital assets.
• Supports tracing of small, repeated transfers dispersed among multiple ephemeral cryptocurrency wallets under the reporting threshold.
• Helps identify patterns of wallet creation and usage consistent with smurfing or structuring in the crypto space.

Implement targeted transaction-monitoring rules that group and analyze sub-threshold values across multiple accounts or senders to detect repeated small-value placements designed to circumvent mandatory reporting thresholds. Upon identifying such patterns, escalate for immediate investigation or limit services to interrupt ongoing structuring.

Leverage specialized blockchain analytics to detect recurring small-value transfers sent to newly generated or ephemeral addresses. Aggregate these sub-threshold transactions over time or across wallet clusters to reveal structuring attempts otherwise concealed by blockchain pseudonymity.

Provide detailed training on identifying structuring typologies, including multiple small deposit patterns designed to avoid thresholds, smurfing using multiple individuals or addresses, and fragmentation strategies in digital assets. Equip staff with scenario-based protocols to escalate suspected structuring promptly.

Assign higher risk ratings to customers exhibiting patterns of distributed, sub-threshold deposits or the use of multiple ephemeral wallet addresses. Apply tighter monitoring scenarios or lower transaction limits to these profiles, ensuring early intervention in potential structuring schemes.

Impose limits or hold periods on the frequency, volume, or cumulative totals of transactions that consistently appear below reporting thresholds. If repeated under-threshold operations or related accounts emerge, suspend those services or mandate additional verification to thwart further structuring attempts.

Continuously re-evaluate customer activity for repeated sub-threshold transactions, looking for deviations such as frequent deposits or withdrawals at values just below official triggers. Investigate and update risk ratings whenever new accounts or addresses exhibit unexplained increments consistent with structuring.

• Offenders deposit multiple low-value amounts into bank accounts, each below automated monitoring triggers for suspicious or large transactions.
• They often use multiple accounts or shell/nominee accounts, making it difficult for financial institutions to detect the overall volume of illicit funds when viewed in isolation.

• Offenders purchase several money orders from different vendors, each under the limit that would trigger identification or scrutiny.
• Depositing or cashing these money orders in separate, smaller transactions helps introduce illicit funds while staying below the radar of suspicious activity monitoring.

• Illicit funds are divided into multiple small crypto transfers, each below the exchange or platform thresholds for heightened due diligence.
• Criminals then distribute these fragmented amounts across numerous newly generated (ephemeral) wallet addresses, complicating oversight of aggregate inflows on public blockchains such as Bitcoin or Ethereum.

• Criminals divide large amounts of illicit cash into multiple small deposits at financial institutions (e.g., below USD/EUR 10,000) to avoid triggering currency transaction reports or other mandatory disclosures.
• By varying the locations and timing of deposits, each transaction remains below official thresholds, making it difficult to detect the aggregation of these sums.

• Criminals load multiple prepaid or stored-value cards with small sums, each remaining under identity verification thresholds.
• Subsequent withdrawals or point-of-sale transactions are similarly fragmented, concealing the funds' illicit origin by preventing any single card from exceeding reporting limits.

• Criminals execute recurring small crypto trades across various accounts to remain under institutional or regulatory thresholds.
• The decentralized, user-driven nature of these trades reduces centralized oversight, facilitating structuring.

• Repeated small deposits or withdrawals via ATMs help criminals stay below official reporting ceilings.
• Offenders can rotate multiple cards or accounts, reducing the likelihood of automated alerts.

• Offenders make numerous micro-payments across multiple user accounts, each falling below required reporting limits.
• Limited identity verification in some P2P platforms further obscures the real source or beneficiary of the funds.

• Criminals deposit illicit proceeds in repeated small increments to avoid higher scrutiny thresholds.
• They subsequently convert these fragmented amounts into various cryptocurrencies, making it harder to trace the overall transaction volume.

• Criminals load numerous prepaid cards with small amounts, collectively exceeding reporting thresholds if aggregated.
• Cards can then be spent or cashed out across different locations, complicating the tracing of overall sums.

• Criminals channel multiple small deposits through business accounts, masking the aggregation under legitimate business activity.
• By spreading transactions across various company accounts, they remain beneath detection trigger levels.

• Repeated small-value top-ups allow criminals to circumvent threshold-based alerts.
• Creation of multiple or ephemeral wallets distributes funds, complicating investigators’ ability to link the overall total.

• Offenders split large sums into numerous low-value transfers that remain below reporting thresholds.
• They use multiple senders, recipients, or remittance outlets to distribute the funds, thwarting suspicious transaction monitoring.

• Through smurfing, illicit funds are funneled in small deposits across numerous personal checking accounts.
• Each deposit is kept under mandatory reporting levels, evading typical bank alerts.

Illicit operators engage in structuring by:

• Splitting large sums of illicit proceeds into multiple sub-threshold deposits or transfers under different accounts or identities.
• Circulating these smaller transactions through financial institutions, remitters, or digital channels to evade reporting triggers.

By maintaining each deposit below detection thresholds, they circumvent standard alerts and frustrate banks' or money service businesses' ability to recognize the aggregated illicit amounts.

Money mules, knowingly or unknowingly, assist in structuring by:

• Accepting or depositing small sums on behalf of illicit operators.
• Withdrawing or transferring these amounts across multiple accounts or locations in rapid succession.

Financial institutions struggle to detect these repeated, low-value transfers when they appear isolated, making it more challenging to identify the total volume of illicit funds.