Smurfing (crime)

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Smurfing is banking industry jargon used to describe the act of splitting a large financial transaction into smaller transactions to avoid scrutiny by regulators or law enforcement. It is commonly used in the context of money laundering and has been known to appear in official Federal criminal indictments. The term is synonymous with "structuring a deposit".

Typically each of these smaller transactions is below some limit, a limit above which financial institutions must file a report with a government agency. Criminal enterprises often send different couriers to make these transactions, and those couriers are known as "smurfs" in this context.

1 United States practice
2 Television origins of smurfing
3 Regulatory Table
4 References
5 External links

[edit] United States practice

In the United States, the Bank Secrecy Act requires the filing of a currency transaction report for transactions of $10,000.00 or more. Financial institutions that suspect structuring of deposits to avoid this limit are required to file a suspicious activity report.

Title 31 of the United States Code, section 5324, provides (in part):

No person shall, for the purpose of evading the reporting requirements of section 5313 (a) or 5325 or any regulation prescribed under any such section, the reporting or recordkeeping requirements imposed by any order issued under section 5326, or the recordkeeping requirements imposed by any regulation prescribed under section 21 of the Federal Deposit Insurance Act or section 123 of Public Law 91–508— [...] (3) structure or assist in structuring, or attempt to structure or assist in structuring, any transaction with one or more domestic financial institutions.

Section 5324 further provides that a violation of this provision may be punished by a fine or up to five years in prison, or both.^[1]

[edit] Television origins of smurfing

The stream of cheery students arriving in the Cayman Islands with packs of money may have reminded law enforcers of The Smurfs because "The Smurfing Song", the 1978 novelty hit by Father Abraham and the Smurfs, began with the words, "Where are you all coming from?" Another possibility is that these deposits are smaller than "normal" size, just as smaller persons are sometimes derisively called Smurfs.

[edit] Regulatory Table

Transaction Limits by Nation, "below what level will I not have to fill out any paperwork"?

Country (alphbetical)	Individual Transaction Limit (persons)	(Weekly or Monthly) Transaction Limit (persons)	Corporate Transaction Limits	data source (link)
Australia	10,000 AUD	None, but splitting to evade the rules is a criminal offence.	Same	^[2]
Brazil	Varies with each kind of transaction.			[1]
Canada	10,000 CAD	Any Transactions adding up to 10,000 in a 24 hour period	Reporting thresholds exist for every deposit. Certain businesses may qualify for a modified reporting structure called Alternative to Large Cash Transaction (ALCT) Reporting	FINTRAC - Financial Transactions and Reports Analysis Centre of Canada
Cayman Islands	None?	None?	None?	None?
Fiji	1,100 FJD	7,700 FJD	Unlimited (investor tourism operators)
France	3,000 EUR
Guyana	10,000 USD
Lithuania	10,000 LTL
Malta	None?	None?	None?	None?
Netherlands	15,000 EUR			[2]
New Zealand	3,000 NZD
Switzerland	None?	None?	None?	None?
USA	10,000 USD