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Layering
Typical severity: MEDIUM
Structuring / Smurfing
Several small outbound transfers to distinct addresses, clustered in a short window, each individually below a materiality floor.
Why it matters
Splitting funds into many small transfers to different addresses is a classic technique for staying under reporting or attention thresholds — a deliberate way to avoid scrutiny rather than an accident of usage.
How we detect it
Look for a burst of several small outbound transfers to distinct addresses within a short time window.
Example evidence
A cluster of small outbound transfers to different addresses within a short window.