Red flag 002 · 9 Oct 2026
Structuring under thresholds
In the city
A red flag is a reason to look, not a verdict.
The Reel as text
The signal
“Structuring VA transactions (e.g. exchange or transfer) in small amounts, or in amounts under record-keeping or reporting thresholds, similar to structuring cash transactions.”
FATF, Virtual Assets Red Flag Indicators, September 2020
Our read
In Türkiye the limit itself makes lawful splits. Per MASAK, platforms cap stablecoin withdrawals at $3,000 a day and $50,000 a month (the limits may be doubled where the travel rule applies), so a larger lawful stablecoin sum leaves in parts.
- Recurring payouts: payroll, freelancers, regular savings
- A small test transfer before the large one
FATF: a red flag is “not necessarily a basis for a suspicion of ML or TF.”
What we would check
- The sum of the transfers across days, linked accounts and assets
- The wallet they go to
- The stated purpose
We would set the alert on the total over the window.
