§2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, Fiscal Year 2022
In fiscal year 2022, 181 of the 185 people sentenced under §2S1.3 (98%) pleaded guilty, and 93% of those guilty pleas came with a written plea agreement. 137 people (74%) were sent to prison, with a median prison term of 12 months.
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Trends › Federal Prosecution Analysis › §2S1.3 Structuring Transactions to Evade Reporting Requireme › §2S1.3: FY2022
In brief: In fiscal year 2022, 181 of the 185 people sentenced under §2S1.3 (98%) pleaded guilty, and 93% of those guilty pleas came with a written plea agreement. 137 people (74%) were sent to prison, with a median prison term of 12 months.
This post uses the U.S. Sentencing Commission's records of 185 people sentenced in federal court in fiscal year 2022. Acquittals and dismissals come from a second source, the Federal Judicial Center's records of 753,808 federal defendants whose cases ended in fiscal years 2016 to 2025. It is part of the Federal Prosecution Analysis series, which builds on Military Moves Toward Sentencing Guidelines to Mirror the Federal System. How the numbers were built: How the Federal Comparison Data Was Built.
Plea Agreements in Nearly Every Guilty Plea
181 people pleaded guilty and 4 were convicted after a trial. Among the guilty pleas, 93% had a written plea agreement. Only 7% were straight pleas with no agreement.
The median prison term after a guilty plea was 12 months. After a trial it was 15 months, based on 3 people who were convicted at trial and sent to prison. With 3 people, the trial figure is only a rough marker.
Prison and Probation
Of the 185 people, 137 (74%) received a prison term, and 33 (18%) received probation only. The median prison term for those sent to prison was 12 months. A quarter received 18 months or more, and a quarter received 4 months or less.
No one in the group was recorded with a mandatory minimum prison term: the count was 0 of 185.
What the Guideline Is Called and What It Counts
In the Guidelines Manual, §2S1.3 is titled "Structuring Transactions to Evade Reporting Requirements; Failure to Report Cash or Monetary Transactions; Failure to File Currency and Monetary Instrument Report; Knowingly Filing False Reports; Bulk Cash Smuggling; Establishing or Maintaining Prohibited Accounts." The Commission records these 185 cases under Money Laundering.
Each person was sentenced between October 1, 2021 and September 30, 2022 and had §2S1.3 as the primary guideline. People who were acquitted or whose cases were dismissed never appear in this data.
Sentences Within and Outside the Range
81 people (44%) were sentenced within the guideline range. 46 (25%) were below it at the government's request. 39 (21%) were below it without a request, and 19 (10%) were above it.
In fiscal year 2021, 38% of §2S1.3 sentences were within the range, and in fiscal year 2023 the share was 46%. Among all guidelines in fiscal year 2022, it was 42%. The §2S1.3 share was about the same as the all-guideline share.
Release Terms, Fines, and Criminal History
128 people (69%) were ordered to serve supervised release after prison, with a median of 36 months. Courts ordered a fine for 26 (14%) and restitution for 16 (9%).
90% were in the lowest criminal history category and 0% in the highest. Courts-martial do not track criminal history in their records.
Comparison With the Whole Federal System
64,142 people were sentenced under all guidelines in fiscal year 2022. Their median prison term was 30 months, and 97% pleaded guilty. The median under §2S1.3 was lower.
Across fiscal years 2016 to 2025, 1,782 people were sentenced under §2S1.3, 75% were sent to prison, the median prison term was 10 months, and guilty pleas were 98%. Fiscal year 2021 had 190 people, with a median of 12 months. Fiscal year 2023 had 172 people, with a median of 9.5 months. The table shows each year.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 257 | 12 months | 97% |
| 2017 | 174 | 12 months | 99% |
| 2018 | 152 | 12 months | 98% |
| 2019 | 177 | 10 months | 98% |
| 2020 | 113 | 10 months | more than 99% |
| 2021 | 190 | 12 months | 99% |
| 2022 | 185 | 12 months | 98% |
| 2023 | 172 | 9.5 months | more than 99% |
| 2024 | 177 | 6.7 months | 98% |
| 2025 | 185 | 8 months | 98% |
Gaps in the Record
The approved crosswalk has no close court-martial counterpart for this guideline, so no military comparison is made. The data does not explain why plea agreements were used so often or what any agreement contained.
How We Counted
Everyone sentenced in federal court in fiscal year 2022 whose primary sentencing guideline was §2S1.3 (185), U.S. Sentencing Commission individual data files. The primary guideline is the one that set the offense level for the most serious count.
Federal fiscal years run from October 1 to September 30. No person, judge, or lawyer is identified in any of these records.
What to Keep in Mind
No parole in federal prison; credit for good conduct. Federal prison has no parole for crimes committed on or after November 1, 1987. A federal prisoner can earn up to 54 days of good conduct credit for each year of the sentence the judge imposed, which is about 15%. Some federal prisoners can also earn First Step Act time credits, but many offenses make a person ineligible. The numbers in this post are the sentences judges imposed, not the time people actually served.
Federal supervised release. Most federal prison sentences are followed by a term of supervised release that the judge sets as part of the sentence. A person who violates it can be sent back to prison. A court-martial cannot sentence anyone to supervision after release. Military parole and mandatory supervised release are decided later by a board, not by the judge at trial.
Who decides the sentence, and under what rules. Federal judges sentence every federal case. They must calculate the Sentencing Guidelines range, which is advisory, and must impose any mandatory minimum the statute requires unless an exception applies. In courts-martial, the accused could choose sentencing by members until the rules changed. For cases in which every guilty finding is for an offense committed after December 27, 2023, a military judge sentences alone, within sentencing parameters. Courts-martial tried in 2024 and later include both old-rule and new-rule cases, and the data cannot tell them apart.
Time periods. Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.
How life sentences and "time served" are counted. In the federal numbers, a life sentence is counted as 470 months, and any other sentence longer than 470 months is counted as just under 470 months. A sentence of "time served" is counted as one day (0.03 months). Averages are affected by these rules; medians much less.
Related Analysis
- Military Moves Toward Sentencing Guidelines to Mirror the Federal System (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- §2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, FY2016–2025 (overview)
- §2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, Fiscal Year 2021 (previous or next fiscal year)
- §2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, Fiscal Year 2023 (previous or next fiscal year)
- How Often Federal Judges Sentence Outside the Guideline Range
- Mandatory Minimums: How Many Federal Sentences Are Set by Congress
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (source)
About the author. Jocelyn C. Stewart is a retired Army JAG with more than 24 years of trying courts-martial and more than 200 jury trials. She hosts Where All The Bodies Are Buried and runs the Law Office of Jocelyn C. Stewart. This analysis is for education and information only. It is not legal advice, and every case is different.