Weekly word: structuring

September 8, 2010

Paul Freeman, an anti-money laundering investigator and educator, defines structuring as “the act of altering a financial transaction to avoid a reporting requirement.”

Criminals in the U.S. know that money services businesses are required to report transactions under the Bank Secrecy Act (BSA) if those transactions occur in a specific manner above a specific amount of money.  So they structure their transactions to fall just under the amount that would trigger a filing.

FinCEN created a 15 minute video about the BSA.  The middle five minutes are especially useful for the examples they include about structuring:

If an MSB suspects that a customer is engaging in structuring, they need to file a Suspicious Activity Report (SAR).  But when you have hawaladars who are in bed with their customers to avoid all reporting requirements, there’s only so much FinCEN can do…


  1. Thank you very much my friend, you are very kind in sharing this useful information with? others…. The details were such a blessing, thanks.

  2. […] sympathizers are also structuring their bank transactions—a classic money laundering technique—in small enough increments […]

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