Structuring / Threshold Avoidance
Deliberate splitting of transactions to remain below reporting thresholds or monitoring triggers. Commonly associated with layering proceeds of crime or avoiding CTR filings.
What it is
Deliberate splitting of transactions to remain below reporting thresholds or monitoring triggers. Commonly associated with layering proceeds of crime or avoiding CTR filings.
Control objective
Identify customers deliberately structuring transactions below monitoring or reporting thresholds to evade detection controls.
Data required
- Individual transaction amounts
- Transaction timestamps (to identify clustering)
- Internal monitoring thresholds (£10k, £15k etc.)
- Customer cumulative daily/weekly totals
- Payment channel used (online, branch, API)
- Beneficiary consistency across structured payments
- Customer profile and declared activity
- Historical baseline transaction sizes
Related typologies (Money Laundering)
Rapid Movement of Funds
Funds received and immediately transferred onward with minimal dwell time, suggesting the account is being used as a pass-through to layer illicit proceeds and obscure audit trails.
Behavioural Change Indicators
Sudden or unexplained changes in a customer's transaction behaviour relative to their established profile, such as new geographies, increased volumes, or different payment types, potentially indicating account takeover or use for laundering.
Mule Account Activity
Accounts used to receive and rapidly disburse funds on behalf of criminal networks. Mule accounts are often opened by individuals who are recruited, coerced, or deceived into facilitating the movement of illicit proceeds.
Shell Company Indicators
Use of corporate entities with no genuine commercial activity to obscure beneficial ownership, layer funds, or create false invoicing chains. Shell companies are commonly used in trade-based money laundering and corruption schemes.
High-Risk Corridor Remittances
Concentration of remittance flows through high-risk corridors where informal value transfer, hawala networks, and limited transparency create elevated ML/TF risks. Particularly relevant for MSBs and EMIs serving diaspora communities.