Answer:
Structuring, as it happens, is a term that is defined in the Treasury Department's Recordkeeping and Reporting regulation (affectionately called the BSA Reg) at 31 CFR 103.11(gg):
[A] person structures a transaction if that person, acting alone, or in conjunction with, or on behalf of, other persons, conducts or attempts to conduct one or more transactions in currency, in any amount, at one or more financial institutions, on one or more days, in any manner, for the purpose of evading the reporting requirements under section 103.22 of this part. "In any manner" includes, but is not limited to, the breaking down of a single sum of currency exceeding $10,000 into smaller sums, including sums at or below $10,000, or the conduct of a transaction, or series of currency transactions, including transactions at or below $10,000. The transaction or transactions need not exceed the $10,000 reporting threshold at any single financial institution on any single day in order to constitute structuring within the meaning of this definition.
Smurfing isn't defined in the regulation. I understand it to mean using a group of individuals to launder money or structure transactions. The group of individuals is large (and apparently unrelated) and the individual transactions are designed to be small enough to avoid detection as a pattern of related transactions.
First published on BankersOnline.com 1/2/07
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