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What is structuring, or smurfing? Why splitting payments raises red flags

By SendPay Business · · 2 min read

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Structuring, sometimes called smurfing, is splitting a large amount of money into smaller deposits or transfers so that each one stays below a reporting or checking limit. It's a common money laundering technique and a major red flag for banks and payment firms.

How it looks

  • Several cash deposits just under a limit, made on the same day or at different branches.
  • Many people ('smurfs') each paying in small amounts that end up in one account.
  • A large payment broken into lots of small transfers.
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US rules

In the US, banks must report cash transactions over $10,000. Deliberately splitting cash to avoid that report is a federal crime, even if the money itself is legal.

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UK rules

The UK doesn't have the same cash reporting limit, but firms must watch for unusual patterns and report suspicions. Structuring to hide criminal money is covered by the money laundering offences in the Proceeds of Crime Act 2002.

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Where SendPay fits

SendPay platforms give your customers GBP, EUR and USD accounts and transfers under your own brand, powered by licensed partners who run the required checks.

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SendPay Business is a technology company, not a bank. Accounts, cards and payments are powered by licensed partners.

Questions people ask

What are the stages of money laundering?

Placement, layering and integration.

Three stages →
What is a suspicious activity report?

How firms report their suspicions.

Suspicious activity reports →
What is transaction monitoring?

Watching payments for suspicious patterns.

Transaction monitoring →

Read next

Spotted a mistake or something out of date? and we'll fix it. How our guides are made

This guide is general information, not legal or financial advice. SendPay Business is a technology company, not a bank, and does not take deposits; regulated services on the platforms are provided by licensed partners. Other companies named in this guide are reference points only and are not affiliated with SendPay Business.