§2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, Fiscal Year 2024
The median prison term under §2S1.3 in fiscal year 2024 was 6.7 months, and a quarter of the people sent to prison received 0.6 months or less. 132 of the 177 people sentenced (75%) received a prison term.
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Trends › Federal Prosecution Analysis › §2S1.3 Structuring Transactions to Evade Reporting Requireme › §2S1.3: FY2024
In brief: The median prison term under §2S1.3 in fiscal year 2024 was 6.7 months, and a quarter of the people sent to prison received 0.6 months or less. 132 of the 177 people sentenced (75%) received a prison term.
This post uses the U.S. Sentencing Commission's records of 177 people sentenced in federal court in fiscal year 2024. 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.
The Lowest Median in the 2016 to 2025 Table
The 6.7 month median for fiscal year 2024 is the lowest in the yearly table for this guideline. The medians in the table for fiscal years 2023 and 2025 were 9.5 months and 8 months. The 2016 to 2025 median was 10 months.
Among the 132 people sent to prison, a quarter received 12.4 months or more. A quarter received 0.6 months or less. The records do not say why terms were shorter, and one year is not a trend.
Probation and Mandatory Minimums
35 people (20%) received probation only, with no prison or other confinement. A mandatory minimum prison term applied to 0 of the 177 people with that information recorded.
Defining §2S1.3
Its full title in the Guidelines Manual is "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 Sentencing Commission assigns these 177 cases to the Money Laundering offense type.
The dates are October 1, 2023 to September 30, 2024. A person is counted here if §2S1.3 set the offense level for the most serious count, and only if the person was convicted and sentenced.
Guilty Pleas Compared With Trial
174 of the 177 people (98%) pleaded guilty, and 3 were convicted after a trial. 89% of the guilty pleas had a written plea agreement, and 11% had none.
After a guilty plea the median prison term was 6.7 months. After a trial it was 46 months, based on 3 people. The gap looks large, but 3 people are too few to say how trial cases generally compare.
Sentences Relative to the Guideline Range
70 people (40%) were sentenced within the range. 62 (35%) were below it at the government's request. 33 (19%) were below it without a request, and 12 (7%) were above it.
In fiscal year 2023, 46% of §2S1.3 sentences were within the range, and in fiscal year 2025 it was 48%. For all guidelines in fiscal year 2024, it was also 46%.
Supervised Release, Fines, and Restitution
116 people (66%) were ordered to serve supervised release after prison, and the median term was 30 months. A fine was ordered for 27 (15%), and restitution for 16 (9%).
93% were in the lowest criminal history category and 0% in the highest. Court-martial records have no equivalent field.
Federal Totals for Fiscal Year 2024
61,678 people were sentenced under all guidelines in fiscal year 2024. The median prison term was 30 months, and 97% pleaded guilty. The 2016 to 2025 count under §2S1.3 was 1,782 people, with 75% sent to prison and 98% pleading guilty. Fiscal year 2023 had 172 people, and fiscal year 2025 had 185. The table shows all years. The approved crosswalk has no close court-martial counterpart for this guideline, so only federal numbers are given.
| 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% |
How We Counted
Everyone sentenced in federal court in fiscal year 2024 whose primary sentencing guideline was §2S1.3 (177), 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 2023 (previous or next fiscal year)
- §2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, Fiscal Year 2025 (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.