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Structuring is a criminal offence under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), and as a remittance operator you can be prosecuted for facilitating it — even if the customer never mentions the word. Structuring occurs when a person deliberately splits transactions to keep each one below the AUD 10,000 threshold that triggers a Threshold Transaction Report (TTR), with the intention of avoiding a reporting obligation. Under section 142 of the AML/CTF Act, both the person who structures and anyone who helps them commit an offence carrying penalties of up to 5 years imprisonment and fines exceeding AUD 130,000.
The risk for your business is rarely the obvious customer who asks you to split a payment. It's the subtle patterns buried in your transaction data — the same beneficiary receiving AUD 9,500 from three different senders on the same day, or a customer who visits four of your agents in a week. If your monitoring program can't surface these, AUSTRAC will treat that as a systemic failure, not an isolated miss.
Key Takeaways
- Structuring is a criminal offence under section 142 of the AML/CTF Act, and facilitating it exposes your business to prosecution and up to 5 years imprisonment for responsible officers.
- The AUD 10,000 TTR threshold is the number structurers target — but structuring also targets thresholds for enhanced due diligence and internal controls.
- You must file a Suspicious Matter Report (SMR) within 3 business days (24 hours for terrorism financing) when you form a suspicion of structuring, regardless of whether the transaction proceeds.
- Effective detection relies on aggregation logic across customers, beneficiaries, agents, and time windows — not single-transaction rules.
- Never tip off a customer that you suspect structuring — tipping off is a separate offence under section 123 carrying up to 2 years imprisonment.
What Counts as Structuring Under the AML/CTF Act
Structuring is defined in section 142 of the AML/CTF Act as conducting transactions in a way designed to avoid a reporting obligation. The offence has two elements: the conduct (splitting or arranging transactions) and the intention (avoiding the report). Intention is what separates a criminal structurer from a customer who happens to send AUD 8,000 twice for legitimate reasons.
The most common target is the AUD 10,000 Threshold Transaction Report obligation. Under section 43 of the Act, you must submit a TTR to AUSTRAC for every cash transaction of AUD 10,000 or more (or the foreign currency equivalent). A structurer breaks a AUD 30,000 transfer into four payments of AUD 7,500 to keep each below the trigger.
Structuring isn't limited to the TTR threshold. Customers also structure to stay below your internal enhanced due diligence (EDD) triggers, source-of-funds verification thresholds, or the limits you set on individual agents. Any deliberate splitting to evade a control is a red flag, even when the amounts sit well under AUD 10,000.
Structuring vs Legitimate Multiple Transactions
Not every customer who sends multiple payments is structuring. A migrant worker who sends AUD 800 to family every fortnight is a normal remittance customer. The distinction is intent to evade — and your job is to identify the patterns that suggest that intent, then apply judgement.
Ask whether the pattern makes commercial sense. A single sender making four AUD 9,000 transfers to the same beneficiary within 48 hours has no legitimate reason to fragment a AUD 36,000 payment. A customer who explicitly asks you to "keep it under ten grand so it doesn't get reported" has removed all doubt about intent.
How Structurers Operate: Common Patterns
Understanding the mechanics of structuring lets you design monitoring rules that catch it. The Financial Action Task Force (FATF) and AUSTRAC typologies describe several recurring methods used across the remittance sector.
Sequential splitting is the simplest form: one customer makes multiple sub-threshold transactions over hours or days. AUD 9,000 on Monday, AUD 8,500 on Tuesday, AUD 9,200 on Wednesday — all to the same beneficiary.
Smurfing uses multiple senders to funnel money to one beneficiary. Five "customers" each send AUD 8,000 to the same overseas account, disguising a single AUD 40,000 transfer as unrelated small payments. In the remittance context, these senders are often recruited within one community and may not understand they're facilitating a crime.
Agent-hopping exploits distributed agent networks. A structurer visits four different agents under your registration, sending AUD 9,000 at each to avoid any single location aggregating the total. This is why your monitoring must aggregate across your entire agent network, not per-outlet.
Channel-mixing combines cash, card, and online funding to obscure the total. A customer funds AUD 6,000 by card online, then walks into an agent to send AUD 5,000 cash to the same beneficiary — keeping each channel's record below thresholds.
A Worked Example
Consider a customer, "Sender A", who sends the following to a single beneficiary in one week:
| Day | Channel | Amount (AUD) | TTR triggered? |
|---|---|---|---|
| Monday | Agent 1 (cash) | 9,200 | No |
| Tuesday | Agent 3 (cash) | 8,800 | No |
| Wednesday | Online (card) | 7,500 | No |
| Friday | Agent 1 (cash) | 9,400 | No |
| Total | 34,900 | 0 TTRs filed |
No single transaction hits AUD 10,000, so no TTR is triggered by threshold logic alone. But the aggregate is AUD 34,900 to one beneficiary in five days, spread across three channels and two agents. This is a textbook structuring pattern — and if your system only checks individual transactions against the threshold, it stays invisible. This scenario should generate an SMR.
Red Flags to Build Into Your Monitoring Program
Your AML/CTF program must include transaction monitoring capable of detecting structuring. AUSTRAC expects your rules to look beyond single transactions and apply aggregation across time, customers, beneficiaries, and channels. Build the following red flags into your monitoring system and staff procedures.
Amount-based flags:
- Multiple transactions just below AUD 10,000 (for example, repeated amounts between AUD 9,000 and AUD 9,999)
- Round or repetitive amounts that suggest deliberate calibration below a threshold
- Transactions sized just under your internal EDD or source-of-funds triggers
Aggregation flags:
- Cumulative sends from one customer exceeding AUD 10,000 within 24–72 hours
- Multiple senders remitting to a single beneficiary within a short window
- One customer sending to multiple beneficiaries who share an address, phone number, or receiving account
Behavioural flags:
- A customer who visits multiple agents to send similar amounts
- A customer who explicitly asks about reporting thresholds or requests you "keep it under" a figure
- Reluctance to complete a transaction once told it will be reported, followed by a request to split it
- Sudden shift from single large transfers to frequent smaller ones after a TTR was previously filed
Network flags:
- Clusters of unrelated customers sending identical amounts to the same corridor and beneficiary
- New customers onboarded together who immediately transact to a common beneficiary
Your monitoring system should aggregate at the customer, beneficiary, and agent level simultaneously. A rule that only sums transactions per customer will miss smurfing; a rule that only sums per beneficiary will miss a single structurer using multiple recipient accounts.
Your Reporting Obligations When You Suspect Structuring
Once you form a suspicion that a customer is structuring, you have a legal obligation to submit a Suspicious Matter Report (SMR) to AUSTRAC under section 41 of the AML/CTF Act. The suspicion threshold is deliberately low — you don't need proof, only a reasonable ground to suspect.
SMR timeframes are strict:
| Suspicion type | Deadline |
|---|---|
| Money laundering / structuring | Within 3 business days of forming the suspicion |
| Terrorism financing | Within 24 hours of forming the suspicion |
Critically, the obligation to report does not depend on whether the transaction goes ahead. If a customer asks you to split a payment and you refuse, you still form a suspicion — and that suspicion is reportable. Declining the transaction does not discharge your SMR obligation.
Your SMR should describe the pattern clearly: the amounts, dates, channels, agents involved, and why the behaviour suggests deliberate avoidance of a reporting threshold. Vague reports frustrate AUSTRAC's Fintel Alliance analysts; specific, well-evidenced reports feed genuine intelligence value.
The Tipping-Off Trap
When you suspect structuring, you must not tell the customer. Tipping off is a separate criminal offence under section 123 of the AML/CTF Act, carrying penalties of up to 2 years imprisonment. You cannot say "I've reported you to AUSTRAC" or even hint that a report has been made.
This creates a practical tension. You may need to decline a transaction, but you must do so without disclosing that an SMR exists. Train front-desk staff to use neutral language — "I'm not able to process this transaction" — rather than referencing reporting or suspicion. Your program should include a documented protocol for handling declined structuring attempts without tipping off.
How to Avoid Facilitating Structuring
Facilitation is the risk that ends careers and de-registers businesses. Under section 142, helping a person structure — including advising them how to stay under thresholds — is itself an offence. Protecting your business requires controls at three levels: staff, systems, and governance.
At the staff level, your front-desk and agent training must cover structuring recognition. Staff must never suggest splitting a transaction, never advise a customer on thresholds, and must escalate any request to "keep it under" the reporting figure. Document this training and refresh it annually — AUSTRAC assessors ask to see training records.
At the systems level, configure your transaction monitoring to aggregate across the dimensions described above and generate alerts for review. Automated flags must route to a person with authority to file an SMR. Retain records of every alert, its review, and the disposition decision for 7 years as required under section 107.
At the governance level, your AML/CTF Compliance Officer should review structuring alerts and SMR trends regularly. If your data shows repeated near-threshold activity in a corridor or agent, treat it as a systemic risk requiring a control response — not a series of one-offs.
Agent Networks Multiply the Risk
If you operate under the Remittance Network Provider (RNP) structure, your affiliates and agents extend your exposure. A structurer who exploits agent-hopping relies on each agent seeing only part of the picture. You are responsible for aggregating agent activity centrally and monitoring it as one network.
Build agent-level oversight into your program: require agents to report transactions in near real time, aggregate them centrally, and monitor for the same beneficiary or sender appearing across multiple outlets. An agent who repeatedly processes sub-threshold transactions to a common corridor warrants investigation.
Structuring Under the 2026 AML/CTF Reforms
The AML/CTF Amendment Act 2024, taking effect through 2026, reinforces the expectation that reporting entities detect structuring proactively. The reforms emphasise outcomes-based compliance — AUSTRAC will judge you on whether your program actually catches the risks it should, not whether you ticked boxes.
For structuring, this means your monitoring rules must be risk-based and demonstrably effective. If your risk assessment identifies high-volume cash corridors as vulnerable to structuring, your controls must reflect that. A generic single-transaction threshold rule will not satisfy an outcomes-based assessment.
The reforms also expand the reporting-entity population and tighten expectations around transaction monitoring documentation. Review your monitoring logic against the structuring typologies in this article and confirm your rules aggregate correctly before the reform provisions bite.
Practical Checklist: Is Your Program Structuring-Ready?
Use this checklist to assess whether your monitoring program can detect and respond to structuring:
- Aggregation logic — Do your rules sum transactions across time windows (24h, 72h, 7 days), not just single payments?
- Multi-dimensional monitoring — Do you aggregate by customer, beneficiary, and agent simultaneously?
- Channel coverage — Do you monitor cash, card, and online funding as a combined view per customer?
- Near-threshold alerts — Do you flag repeated amounts between AUD 9,000 and AUD 9,999?
- Staff training — Can front-desk staff recognise a structuring request and escalate without tipping off?
- SMR workflow — Can you file an SMR within 3 business days, with a documented review trail?
- Tipping-off protocol — Do staff know how to decline a transaction without disclosing suspicion?
- Record-keeping — Do you retain alerts, reviews, and decisions for 7 years?
- Governance review — Does your Compliance Officer review structuring trends and adjust controls?
If you answer no to any of these, prioritise the gap before your next AUSTRAC compliance assessment.
Bringing It Together
Structuring is one of the clearest lines between a compliant remittance business and a facilitator of financial crime. The difference isn't whether structurers try to use your service — they will — but whether your program detects the pattern, files the report, and refuses to help. Build aggregation into your monitoring, train your staff to recognise and escalate, and treat every near-threshold cluster as a question worth answering.
Review your transaction monitoring rules against the red flags above, and pressure-test your SMR workflow so you can meet the 3-business-day deadline every time. Use our AML/CTF Program builder to document your structuring controls, and explore our corridor guides to understand where structuring risk concentrates in your key markets.
This information is general in nature and does not constitute legal advice. Consult AUSTRAC or a qualified legal professional for advice specific to your situation.
Frequently Asked Questions
What is the difference between structuring and money laundering?
Money laundering is the broader process of disguising the origins of illicit funds. Structuring is a specific method — splitting transactions to avoid triggering a reporting obligation like the AUD 10,000 Threshold Transaction Report. Structuring is a standalone offence under section 142 of the AML/CTF Act, and it can occur with either legitimate or illicit funds, because the offence targets the evasion of reporting, not the source of the money.
Do I have to file an SMR if I refuse a structuring transaction?
Yes. Your Suspicious Matter Report obligation arises the moment you form a suspicion — not when the transaction completes. If a customer asks you to split a payment to avoid reporting and you decline, you have still formed a reasonable suspicion of structuring. You must file the SMR within 3 business days (24 hours for terrorism financing), even though no transaction was processed.
Can I tell a customer their transaction will be reported to AUSTRAC?
You can explain that transactions of AUD 10,000 or more are routinely reported as a Threshold Transaction Report, because that is a general regulatory fact. However, you must never tell a customer you have filed or intend to file a Suspicious Matter Report about them. Tipping off is a separate offence under section 123 of the AML/CTF Act, carrying up to 2 years imprisonment. Train staff to decline transactions using neutral language.
How long do I need to keep records of structuring alerts?
Under section 107 of the AML/CTF Act, you must retain transaction and monitoring records — including structuring alerts, your review of each, and the disposition decision — for 7 years. AUSTRAC assessors will ask to see this trail during a compliance assessment, so ensure your monitoring system logs the full lifecycle of each alert.
What amounts should trigger a structuring alert in my monitoring system?
Focus on near-threshold and aggregation patterns rather than a single figure. Flag repeated transactions between AUD 9,000 and AUD 9,999, cumulative sends exceeding AUD 10,000 from one customer within 24–72 hours, multiple senders remitting to a single beneficiary in a short window, and one customer sending sub-threshold amounts across multiple agents or channels. The threshold value is AUD 10,000, but structurers deliberately sit below it, so your rules must catch the pattern, not the single number.
