Part IV: Financial Fraud · Chip, Cash & Ticket Fraud

Structuring / Smurfing to Avoid CTR Reporting

How it works

Criminals break large cash transactions into multiple smaller transactions to avoid the $10,000 Currency Transaction Report (CTR) threshold. Examples include: purchasing $7,500 in chips from one dealer and $7,500 from another; making $9,000 payments on a marker over multiple days; a couple splitting $18,000 in chip redemptions between two cages; purchasing four $2,900 casino checks instead of one $11,600 check. The AGA Best Practices document provides multiple examples of structuring schemes. “Smurfing” extends this by using multiple individuals (runners) to make geographically dispersed transactions below reporting thresholds.

Where it appears

Cage, multiple table games, TITO kiosks, sports book windows

On the record

Structuring is a federal crime punishable by up to 5 years imprisonment and $250,000 fines (doubled if over $100,000 in 12 months or involving another federal violation). FinCEN’s 2007 rule change exempting slot jackpots from CTRs reduced total casino CTR filings by 35% but increased focus on more suspicious transaction types.

Published as a detection reference for surveillance, compliance and gaming-operations professionals. Thresholds and tuning are set by the property. Nothing here is instruction: the method is described so it can be recognised.