Kingsfield · Research · Banking & Financial Services

Is it illegal to break a cash deposit into smaller amounts to stay under the currency reporting threshold?

Published 2026-06-23 · U.S. federal law

Section 5324 makes it unlawful to structure a transaction with a financial institution for the purpose of evading the currency-transaction reporting requirements, even if no single transaction would otherwise trigger a report.

The answer

The prohibition

31 U.S.C. § 5324 bars any person, for the purpose of evading the reporting requirements of section 5313 (or its regulations), from structuring, assisting in structuring, or attempting to structure any transaction with one or more domestic financial institutions.

Why intent matters

The offense turns on purpose. The conduct is splitting or arranging deposits so each falls below the reporting threshold, done with the specific aim of evading the report a financial institution would otherwise file.

The judged input

What the AI drafted

Submitted to the judge

This is an excerpt from a draft BSA/AML compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites two authorities; one of them is wrong.

AI draft excerpt — BSA/AML compliance memo

The customer's pattern of making multiple sub-$10,000 cash deposits across branches on the same day raises a structuring concern. Under 31 U.S.C. § 5324, no person may structure a transaction with one or more domestic financial institutions for the purpose of evading the currency-reporting requirements. We note that the conduct is independently criminalized by the reporting statute, 31 U.S.C. § 5313, which on its face prohibits breaking deposits into smaller amounts to avoid a report. We advise filing a SAR and escalating to the BSA officer.

The judge ruled on every citation as the draft used it — it accepted 31 U.S.C. § 5324 and rejected 31 U.S.C. § 5313. Here is why.

The verdict

How Kingsfield ruled

Ruled 2026-06-23

Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.

Accept31 U.S.C. § 5324

The draft claimed: No person shall, for the purpose of evading the reporting requirements of section 5313 or its regulations, structure, assist in structuring, or attempt to structure any transaction with one or more domestic financial institutions.

“§ 5324 No person shall, for the purpose of evading the reporting requirements of section 5313(a) or 5325 or any regulation prescribed under any such section, the reporting or recordkeeping requirements imposed by any order issued under section 5326, or the recordkeeping requirements imposed by any regulation prescribed under section 21 of the Federal…”

Cite found; proposition supported by the cited text.

Reject31 U.S.C. § 5313

The draft claimed: Section 5313 prohibits breaking cash deposits into smaller amounts for the purpose of evading the currency-transaction report, making structuring a crime.

Cite found, but the cited text does not support the claim. 31 U.S.C. 5313 imposes the affirmative duty on financial institutions to file currency transaction reports for transactions over the threshold; the anti-structuring prohibition is at 31 U.S.C. 5324. Regenerate with the correct authority.

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This page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.