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Finance glossary

What is smurfing and how does it work?

Bristol James
4 Min

Smurfing is a money laundering technique where individuals break down large sums of money into smaller transactions to avoid detection by regulatory authorities. This illegal practice involves spreading out these smaller transactions across multiple accounts to stay below reporting thresholds and evade scrutiny by regulatory agencies.

Smurfing can have serious legal consequences and is considered a form of financial fraud. In this blog post, we explore the concept of smurfing, how it works, and how to prevent it.

How does smurfing work?

Smurfing in the context of money laundering involves breaking down large sums of money into smaller, less suspicious amounts to evade regulatory reporting requirements. Criminals—in this case, called “smurfs”—employ this technique to evade detection by authorities and integrate illicit gains into the financial system without raising suspicion.

What is smurfing and what is a smurf?
Sadly, we’re not talking about this kind of smurf.

The process of smurfing unfolds through three stages:

  1. Placement. Initially, criminals deposit illegally obtained cash into various bank accounts. To evade detection, they divide large sums into smaller deposits spread across multiple accounts. The goal of this step is to integrate illicit funds into the legitimate financial system without raising suspicion.
  2. Layering. During the layering stage, laundered money undergoes a sophisticated series of transactions designed to conceal its origin and obscure the audit trail. Criminals may transfer funds electronically between accounts, move money across borders, or invest in assets like stocks, real estate, or businesses. These actions obfuscate the source of the funds and create a convoluted financial trail that makes tracking difficult for authorities.
  3. Integration. In the final stage, laundered funds are reintegrated into the economy as seemingly legitimate wealth. Criminals seek to extract their illicit gains without attracting attention. This may involve purchasing assets such as property, artwork, jewelry, or luxury vehicles, which can be sold or used to fund further criminal activities.

Financial institutions and law enforcement agencies actively work to detect and prevent smurfing due to its detrimental impact on the integrity of the financial system and society as a whole. By understanding the intricacies of smurfing and implementing robust measures to combat it, authorities can mitigate the risks posed by this illicit activity and safeguard the integrity of the global financial infrastructure.

What is the difference between smurfing and structuring?

Smurfing and structuring are closely related concepts in the realm of financial crime: both involve the division of large sums of money into smaller transactions to circumvent regulatory oversight. However, even though they share similarities in their modus operandi, there are fundamental distinctions between the two practices.

While both smurfing and structuring involve dividing substantial sums of cash into smaller transactions, their key differences lie in their goals and methods. Smurfing entails breaking down a large amount of money into smaller transactions that fall below the reporting threshold set by regulatory bodies. The aim of smurfing is to evade detection by financial institutions, which are mandated to report cash transactions surpassing a specific limit.

On the other hand, structuring involves fragmenting larger deposits into smaller sums to circumvent reporting requirements. For example, an individual might opt to make ten deposits of $5,500 each instead of a single $55,000 deposit, thus avoiding triggering the deposit reporting mandate. Structuring primarily seeks to escape scrutiny from regulatory agencies while adhering to standard reporting thresholds outlined in anti-money laundering (AML) protocols.

Unlike smurfing, structuring may not require the involvement of multiple parties or accounts. Often, it revolves around a single entity making numerous deposits just below the reporting threshold. However, both smurfing and structuring are considered illicit activities, violating AML regulations and carrying severe legal consequences.

Common targets of smurfing

Smurfing is a particularly attractive money laundering tactic in various industries, including:

  • The anonymity of cryptocurrency transactions attracts money launderers, who exploit the market’s lack of transparency despite KYC compliance requirements.
  • Criminals exploit virtual currency purchases to launder funds, converting them back into real money through legitimate channels.
  • Real estate. Smurfs use short-term mortgages and property purchases to launder illicit funds, often complicating law enforcement efforts.
  • Financial institutions. Money launderers utilize a network of interconnected accounts to obscure the source of funds, making tracing difficult for financial institutions.
  • Money services businesses (MSBs). MSBs, like money transfer services and digital payment platforms, are vulnerable due to their handling of large sums of money, requiring robust AML measures.

How to prevent smurfing?

Preventing smurfing requires solid AML measures, especially in industries prone to such activities. Despite regulations mandating advanced customer due diligence, non-compliance cases are increasing annually.

Key prevention strategies involve adhering to five key pillars of AML. This includes appointing a compliance officer, conducting risk assessments, establishing internal controls and AML policies, continuously monitoring and auditing AML programs, and implementing Customer Due Diligence (CDD) practices.

Another crucial aspect is adopting a risk-based approach. This entails identity verification through strong Know Your Customer (KYC) measures tailored to specific industry risks. Companies should conduct thorough risk assessments to prioritize vulnerabilities and allocate resources efficiently.

Customer risk profiling is essential, categorizing customers into different risk levels and applying enhanced due diligence (EDD) to high-risk individuals or entities. Additionally, implementing real-time transaction monitoring systems is vital for flagging and investigating suspicious transactions, which is crucial for detecting smurfing activities.

Key takeaways

  • Smurfing is a money laundering technique involving the division of large sums of money into smaller transactions to evade detection by regulatory authorities.
  • The process of smurfing involves three stages: placement, layering, and integration, where illicit funds are deposited, layered through complex transactions, and reintegrated into the economy as legitimate wealth.
  • Unlike structuring, which fragments larger deposits to circumvent reporting requirements, smurfing aims to keep transactions below reporting thresholds to avoid scrutiny.
  • Industries prone to smurfing include crypto, gaming, real estate, financial institutions, and money services businesses.
  • Prevention strategies include adhering to AML pillars, implementing a risk-based approach, conducting customer risk profiling, and implementing real-time transaction monitoring systems.





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