What is structuring in money laundering — how do you train new analysts?

by :name Tomás Herrera · Anti-Money Laundering (AML) · Mar 22, 2026 · 2 replies Answered

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I'm putting together training materials for new AML analysts and I'm trying to explain structuring in money laundering in a way that goes beyond the textbook definition.

Every analyst knows that structuring is breaking up transactions to avoid the $10,000 CTR threshold. But in practice it's more nuanced than that. Our newer analysts struggle to distinguish between customers who are genuinely making multiple small deposits (small business owners, restaurant workers) and those who are actually structuring.

How do you teach the difference? What real-world structuring money laundering patterns do you include in your training? And how do you handle the gray areas where the intent is ambiguous?

Tomás Herrera

Member since Apr 2026

Accepted Answer

Training on structuring money laundering is tricky because the line between suspicious and normal is genuinely blurry. Here's what works in our training program:

Pattern recognition over single transactions. We teach analysts to look at the full picture over 30-60 days, not individual deposits. One $9,500 deposit means nothing. Five $9,500 deposits across different branches in a week from someone who's never made cash deposits before? That's a pattern.

Context matters more than amounts. We show examples where the amounts themselves aren't suspicious but the behavior is — like a customer who always deposits cash on Monday mornings, always at a different branch, always just under reporting thresholds. Structuring in money laundering is about the intent to evade reporting, not just the dollar amount.

False positive calibration. We pair every suspicious example with a legitimate one that looks similar. A cash-intensive restaurant depositing $8,000 three times a week is probably normal. The same deposits from a salaried employee are suspicious.

The best structuring money laundering training I've seen uses real (anonymized) cases from your own institution. Abstract examples are less effective than showing new analysts what structuring actually looked like in your customer base.

Nadia Osei

Member since Apr 2026

2 replies

One thing to emphasize in training: structuring is illegal regardless of whether the underlying funds are legitimate. A customer who breaks up clean cash deposits to avoid CTRs is still committing a federal crime. This trips up some analysts who think "well the money is legal so it's not really money laundering."

Also worth covering: structuring isn't limited to cash deposits. Anti money laundering structuring patterns also appear in wire transfers, monetary instrument purchases (cashier's checks, money orders), and even cryptocurrency transactions. The $10k threshold is the most well-known trigger but it's not the only one.

For the gray areas: document the analyst's reasoning either way. If they decide the activity is NOT structuring, the documentation should explain why. "Customer is a known cash-intensive business with consistent deposit patterns" is defensible. No documentation at all is not.

LexFlag Team

Mar 23, 2026 at 12:47 PM