TL;DR: Structuring, or smurfing, breaks large cash movements into smaller deposits below reporting thresholds, while AI-generated identities and deepfakes make account creation and coordination harder to detect, according to Veriff's analysis and Fraud Index 2025. The lesson for financial institutions is that transaction monitoring alone is not enough when identity proofing, mule-account creation, and reporting workflows are all under pressure.
Editorial analysis by NHI Mgmt Group, based on content published by Veriff: “Estructuración, fraude y el futuro de la seguridad bancaria”.
By the numbers:
- The Veriff Fraud Index 2025 reports a 21% year-on-year increase in online fraud since 2024.
- The Veriff Fraud Index found that almost 79% of people have been targeted by AI-generated fraud or deepfakes at least once in the last year.
- More than 97% of people believe strong security measures matter when signing up for a new financial service, according to Veriff's Fraud Index 2025.
Key questions
Q: What breaks when AML programmes rely mainly on transaction thresholds?
A: Threshold-based monitoring misses structuring because the behaviour is distributed across smaller deposits that look ordinary in isolation.
Q: Why do synthetic identities make structuring harder to detect?
A: Synthetic identities let criminals create mule accounts that look legitimate enough to pass onboarding and then absorb structured deposits.
Q: How should financial institutions connect identity proofing to AML monitoring?
A: They should treat onboarding confidence as an input to AML triage, not a separate compliance step.
Practitioner guidance
- Strengthen identity proofing for high-risk account types Use stronger document, biometric, and liveness checks where accounts can be used for cash-heavy or rapid-deposit behaviour, especially when synthetic identity risk is elevated.
- Correlate deposits across branches and institutions Tune AML rules to join sub-threshold deposits by timing, geography, and shared identity signals so structuring appears as one behavioural pattern rather than many small events.
- Join onboarding risk to transaction monitoring Feed identity-verification confidence into AML triage so accounts opened with weaker assurance are reviewed with lower thresholds and tighter behavioural scrutiny.
Bottom line: Structuring defeats AML programmes when deposits are assessed one by one instead of as a coordinated pattern across accounts and channels.
Explore further
View Full Forum → | NHI Foundation Course → | Our Services → | Read the full analysis →
Structuring is a control-gap problem, not just a transaction-size problem. The article shows that splitting payments into sub-threshold amounts defeats alerting when monitoring logic is too local. AML programmes that evaluate each deposit in isolation are already behind the behaviour they are meant to govern. The practitioner conclusion is that structuring detection has to be built around patterns, not thresholds alone.
A question worth separating out:
Q: How can teams tell whether suspicious-activity reporting is working?
A: A good test is whether the system can build a complete case from linked identities, deposits, timing, and locations without manual reconstruction. If SARs still depend on analysts stitching together disconnected alerts, the reporting workflow is descriptive rather than investigative and will lag structured laundering patterns.
👉 Read our full editorial: Structuring exposes the limits of identity-led AML controls