Part III: Business & Regulation · Gaming Regulation & Compliance

Structuring

AML/CFT

The practice of breaking a large currency transaction into multiple smaller transactions, each below the $10,000 CTR reporting threshold, to evade detection and avoid mandatory reporting requirements. Structuring is illegal regardless of whether the underlying funds were obtained legitimately. Common structuring indicators include multiple deposits or withdrawals just below the threshold, transactions conducted across multiple shifts or casino locations, and the use of multiple individuals to conduct related transactions. Casino staff and surveillance must be trained to recognize and report structuring patterns.

In practice

Also known as “smurfing” in some contexts, though SMURFing typically refers to using multiple individuals (“smurfs”) to conduct transactions.

One entry from the Casino Industry Glossary — 1,157 terms written for surveillance, compliance and operations professionals rather than for players. Definitions describe industry usage; where a term carries a regulatory meaning, verify against the instrument that governs your jurisdiction.