What is the Difference Between Smurfing and Structuring?

Team FOCAL
January 28, 2024

Smurfing and structuring may seem similar, and people sometimes use them interchangeably. However, they have different meanings and apply in specific situations when it comes to financial transactions.

Both smurfing and structuring are against the law and can lead to serious legal consequences because they are linked to money laundering and efforts to evade financial rules. So, what is smurfing in money laundering, and how does it differ from structuring in money laundering?

What is Smurfing?

Smurfing is a way of hiding illegal money by breaking it into smaller, less noticeable amounts. In smurfing, people called "smurfs" make small transactions at different banks to make it hard for authorities to find the original source of the money. This is more complicated than regular structuring in money laundering and uses tricky methods to hide where the money comes from. Smurfing is illegal and has serious consequences. Financial institutions need to watch out for unusual cash deposits to catch and stop smurfing.

Smurfing in money laundering involves a group of people called "smurfs," who are usually lower-level criminals. They carry out planned transactions at different banks and times, making it difficult to track the money back to the main person behind it.

The word "smurf" comes from illegal drug groups and means junior money launderers or runners in this context. The process happens in three steps: placement, layering, and integration, similar to the stages of money laundering.

Examples of Smurfing

Below are three examples of smurfing:

  1. Cash Divide: If someone has, let’s say, $15,000. Instead of depositing it all at once in a bank, they ask a few friends to each deposit $5,000 in different banks. This way, it's not one big amount that might attract attention.
  1. Shopping Trick: A group of people with illegal money buys expensive things, like TVs or jewelry. Instead of making one big purchase, they make many small buys at different stores. This helps hide the fact that they're spending a lot of money.
  1. Cuckoo Smurfing: Let's say someone in the UAE owes money to someone in the KSA. Instead of sending the money directly, they get a friend in the KSA to pay the debt using their own legal money. The friend doesn't know it's part of something illegal, and it seems like a regular transaction. And this is called cuckoo smurfing.
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What is Structuring?

Structuring is a trick people use with money. They break down big transactions into smaller parts to avoid rules and reporting. To avoid regulatory detection and Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) reporting requirements, money launderers employ this "placement" method to make multiple deposits while staying below cash reporting thresholds.

If someone keeps making small deposits just under the limit set by the rules, it can raise suspicions and red flags. Structuring is not only against the law, but it also signals possible illegal activities.

Example of Structuring

Structuring is breaking down a large amount into smaller parts to hide it from the bank or authorities. So an example of structuring would be: if someone has $30,000, instead of putting it all in the bank at once, they might do it slowly, like $10,000 each time, so it doesn't raise any alarms.

But the question is, what is the difference between smurfing and structuring?

What is the Difference Between Smurfing and Structuring?

While both smurfing and structuring entail breaking down large sums into smaller transactions and are often used interchangeably, their key differences lie in their purpose and execution. Smurfing aims to hide the true nature and source of funds, involving multiple individuals and being more challenging to detect. On the other hand, structuring is focused on avoiding reporting requirements, often managed by a single individual and detected through monitoring patterns near the reporting threshold.

Criteria

Smurfing

Structuring

Purpose

Concealing the true nature and source of funds

Avoiding reporting requirements, not always concealing the source

Complexity

More complex, involves multiple individuals

Simpler, often managed by a single individual

Detection Difficulty

Challenging to detect due to complexity

Comparatively easier to detect, often through monitoring

Number of Individuals Involved

Involves multiple individuals (smurfs)

Usually carried out by a single person

Legality

Illegal

Illegal

Source of Funds

Often involves illegally obtained money    

Can involve legally obtained money, may not always conceal the source

Geographical Involvement

Often crosses geographical boundaries

Generally simpler, may not involve extensive geographical movement

Method of Execution

Multiple individuals making numerous deposits

A single individual making several deposits near the reporting limit

AML Compliance: Structuring and Smurfing

Anti-Money Laundering (AML) regulations focus on preventing financial crimes such as smurfing and structuring. Below is an overview of how this happens:

1. Reporting Thresholds

AML regulations globally establish reporting thresholds to identify potential instances of structuring and smurfing.

In the US and other countries like Canada, Ireland, Australia, and Sweden, transactions exceeding $10,000 (including foreign currencies) must be reported.

2. Suspicious Activity Reporting (SAR)

Financial institutions are legally bound to submit Suspicious Activity Reports (SARs) if they suspect structuring.

3. Key Components of AML Regulations

AML regulations worldwide focus on:

  • Reporting Requirements: Mandating reporting of transactions surpassing specified thresholds to identify potential structuring or smurfing attempts.
  • Currency Transaction Reports (CTRs): Obligating financial institutions to file CTRs for cash transactions above designated thresholds, aiding in monitoring suspicious activities.
  • Suspicious Activity Reports (SARs): Requiring the submission of SARs upon identifying transactions indicative of money laundering, triggering a further investigation.
  • Know Your Customer (KYC) Procedures: Establishing strong KYC procedures for verifying customer identities and assessing risk profiles, forming a frontline defense against illicit financial activities.

4. Penalties and Enforcement

Regulatory agencies and law enforcement impose significant penalties, including fines, imprisonment, asset forfeiture, and reputational damage. Learn more about The Top AML Fines and Penalties You Should Avoid in 2024

Detecting and Preventing Smurfing and Structuring

Detecting and preventing smurfing and structuring is an ongoing process; as long as the customer is making transactions, there is a possibility they might be smurfing or structuring money. Below are ways that can help you detect and prevent these illegal actions:

1. Watchful Transactions

  • Look for patterns like small deposits and sudden changes in accounts.

2. Automated AML Tools

  • Utilize AML tools like FOCAL, which provides screening, monitoring, and risk scoring. FOCAL enables you to quickly analyze large transactions for suspicious patterns.

3. Training Staff

  • Regular training helps staff spot signs of smurfing and structuring.
  • Ensures staff know what to do when they suspect something.
  • Training helps teams spot red flags for structuring and smurfing.
  1. Red Flags include
  •    Small deposits just below $10,000.
  •    Daily deposits exceeding limits.
  •    Same-day cash deposits at different places.
  •    Multiple sign-ups with common details.
  •    Customers give unclear reasons for transactions.

4. Risk Check

  • Regular assessments find weak points and help identify areas prone to structuring or smurfing.

5. Understanding Criminal Methods

  • AML professionals stay informed about criminal methods.

Conclusion

In conclusion, both smurfing and structuring involve breaking down large sums into smaller transactions, but they differ in their purpose and how they are done. Smurfing tries to hide the true nature of funds and involves many people, making it harder to notice. On the flip side, structuring aims to avoid reporting requirements and is usually done by one person, often detected by monitoring transactions near the reporting limit.

In simpler terms, smurfing is more complex and involves a group of people, while structuring is simpler and usually done by an individual. Both are used to handle money in ways that can be against the rules. A comprehensive AML platform, like FOCAL, works in real-time, alerting institutions. Using advanced algorithms, FOCAL fights financial crime effectively.

FAQs

Q1. What is smurfing in money laundering?

Smurfing involves breaking down large sums of money into smaller transactions to avoid detection, often used for illegal purposes.

Q2. What is structuring in money laundering?

Structuring in money laundering involves manipulating transactions to avoid reporting thresholds.

Q3. What is structuring in banking?

Structuring in banking refers to the deliberate design of financial transactions to avoid triggering regulatory thresholds or reporting requirements, often associated with money laundering.

Q4. What legal consequences come with smurfing and structuring?

Engaging in smurfing or structuring can lead to significant legal penalties, including fines, imprisonment, asset forfeiture, and reputational damage.

Q5. What are common signs or red flags indicating potential smurfing activities?

Red flags may include making multiple small deposits just below reporting thresholds, frequent round-number transactions, and abrupt changes in account activity.

Q6. How do financial institutions contribute to preventing smurfing and structuring?

Financial institutions implement measures such as reporting requirements, transaction monitoring, and filing Suspicious Activity Reports (SARs) to identify and prevent smurfing and structuring.

Q7. What industries are at higher risk for smurfing and structuring?

Industries with high cash flow, like casinos, money services businesses, and certain types of retail, are often considered at higher risk for smurfing and structuring.

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