Structuring — The Money Laundering Technique Hiding in Plain Sight
It’s one of the most common red flags in gaming venues. Here’s how to spot it.
What Is Structuring?
Structuring (sometimes called “smurfing”) is deliberately breaking a transaction into smaller amounts to avoid triggering identification or reporting thresholds.
With the new $5,000 CDD threshold from 31 March 2026, structuring looks like this:
What a structurer does
Requests three separate payouts of $4,500 across a single session — totalling $13,500 — to stay under the $5,000 ID threshold each time.
What should happen
Staff recognise the pattern, escalate to the compliance officer, and an SMR is filed with AUSTRAC.
Three Structuring Patterns to Watch For
1. Amount Clustering
Multiple payouts just below the threshold — $4,800, $4,900, $4,950. The amounts are suspiciously close to $5,000 without ever reaching it.
What to look for: Same patron, same day or across consecutive days, amounts consistently just under $5,000.
2. Velocity Spikes
A patron who normally has modest gaming activity suddenly has a day with multiple large payouts. The total is well above $5,000 but each individual payout is below.
What to look for: Unusual frequency of payouts for a particular patron. A pattern that doesn’t match their normal behaviour.
3. Split Payouts
A patron wins $8,000 on a machine and asks to be paid in two instalments of $4,000 each, or asks a companion to collect part of the payout.
What to look for: Requests to split a single win into multiple payouts. Third parties collecting payouts. Multiple people cashing out from the same machine in quick succession.
Real-World Scenarios
A patron who normally plays $50–$100 sessions starts coming in every Thursday and requesting payouts of $4,800–$4,900. Over a month, they’ve collected $19,400 in cash without ever triggering ID requirements. This is a textbook structuring pattern.
A man plays a gaming machine and accumulates a $7,000 credit. Instead of cashing out himself (which would require ID), his partner cashes out $3,500 and he cashes out $3,500 separately. This is a split payout designed to avoid identification.
A patron moves between three machines over an hour, cashing out $4,000 from each. Total: $12,000 in cash, no ID required for any individual payout. Staff at different stations may not realise the same person is doing this.
Why Structuring Matters
Structuring is a criminal offence under Australian law. But more importantly for your venue, failing to detect and report structuring is a compliance failure that AUSTRAC takes seriously.
AUSTRAC CEO Brendan Thomas has specifically called out “bill-stuffing” — inserting large amounts of cash into gaming machines with minimal gameplay before cashing out as apparently legitimate winnings. This is structuring in action.
AUSTRAC has explicitly stated that monitoring systems relying heavily on manual observation by staff — rather than structured, risk-based systems — are inadequate. You need systematic monitoring.
What to Do When You Spot Structuring
- Don’t confront the patron — continue providing normal service
- Document what you observed — times, amounts, machine numbers, patron description
- Escalate immediately to your compliance officer or venue manager
- File an SMR with AUSTRAC within 3 business days
- Do not tip off the patron that you’ve noticed or reported their behaviour
- Record the incident in your venue’s compliance system for future reference
Prevention: Systems Over Observation
- Track daily aggregate payouts per patron — not just individual transactions
- Flag payouts above 80% of the threshold ($4,000+) for review
- Monitor payout frequency — multiple payouts in a single session or day
- Cross-reference across staff shifts — a patron may structure across shift changes
- Train all payout staff to recognise and escalate the three patterns above
- Use technology — automated alerts are more reliable than manual observation
References
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) — legislation.gov.au
- AUSTRAC, AML/CTF tips for pubs and clubs with gaming machines — austrac.gov.au
- AUSTRAC, Suspicious matter reports — austrac.gov.au
- AUSTRAC, Regulatory Expectations and Priorities 2025–26 — austrac.gov.au
Detect structuring automatically
ComplyIQ monitors daily aggregates, flags clustering patterns, and alerts your compliance team in real time. Stop relying on manual observation.