Jury Instruction - Evading Currency Transaction Reporting Requirement While Violating Another Law By Structuring Transaction 2025

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Structuring is governed by Federal Statute 31 USC 5324 and states in pertinent part that, no person shall for the purpose of avoiding a financial transaction reporting requirement, cause or attempt to cause a domestic financial institution or nonfinancial trade or business to fail to file a required financial report.
A structured transaction is a series of related transactions that could have been conducted as one transaction, but the financial institution and/or the transactor intentionally broke it into several transactions for the purpose of circumventing the reporting requirements of the Bank Secrecy Act (BSA).
Designing a transaction to evade triggering a reporting or recordkeeping requirement is called structuring. Structuring is a federal crime, and must be reported by filing a Suspicious Activity Report (SAR). Examples 1. A customer breaks a large transaction into two or more smaller transactions.
Federal law requires financial institutions to report currency (cash or coin) transactions over $10,000 conducted by, or on behalf of, one person, as well as multiple currency transactions that aggregate to be over $10,000 in a single day. These transactions are reported on Currency Transaction Reports (CTRs).
Title 31 U.S.C. 5324 makes it a federal crime for any person or entity to knowingly structure or attempt to structure any transaction with the intent to evade reporting requirements.
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Structuring is where a person deliberately: splits cash transactions to avoid a single large transaction being reported in threshold transaction reports. travels with cash amounts in a way that avoids declaring cross border movements of the cash.
31 U.S. Code 5324 - Structuring transactions to evade reporting requirement prohibited. structure or assist in structuring, or attempt to structure or assist in structuring, any transaction with one or more domestic financial institutions.
Definition. Structuring is the act of parceling what would otherwise be a large financial transaction into a series of smaller transactions to avoid scrutiny by regulators and law enforcement.

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