Structuring is the legal term to describe the issue of transactions structured
to avoid certain record keeping and reporting requirements mandated by law.
Sometimes referenced as smurfing in banking
industry jargon, structuring
includes the act of parceling large financial transactions into smaller
transactions to avoid scrutiny by regulators
or law enforcement. Structuring often appears in indictments related
to fraud, money laundering, and other financial
crimes such as identity theft.
Typically each of the smaller transaction is below some statutory limit,
that does not require a financial institution to file a report with a government agency. Criminal enterprises often employ several agents (smurfs)
to make the transaction