§2S1.3 Structuring Transactions to Evade Reporting Requirements: Federal Sentences, Fiscal Year 2025
In fiscal year 2025, 89 of the 185 people sentenced under §2S1.3 (48%) received a sentence within the guideline range. 143 (77%) were sent to prison, and the median prison term was 8 months.
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Trends › Federal Prosecution Analysis › §2S1.3 Structuring Transactions to Evade Reporting Requireme › §2S1.3: FY2025
In brief: In fiscal year 2025, 89 of the 185 people sentenced under §2S1.3 (48%) received a sentence within the guideline range. 143 (77%) were sent to prison, and the median prison term was 8 months.
This post uses the U.S. Sentencing Commission's records of 185 people sentenced in federal court in fiscal year 2025. 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.
Within the Range for 48% of the Group
The share of sentences within the guideline range was 48% in fiscal year 2025, compared with 40% in fiscal year 2024. For all guidelines in fiscal year 2025 it was 51%.
The other sentences were 43 below the range at the government's request (23%), 41 below the range without a request (22%), and 12 above the range (6%).
Prison Terms in Fiscal Year 2025
Of the 185 people, 143 (77%) received a prison term, and 32 (17%) received probation only. The median prison term for those sent to prison was 8 months. In fiscal year 2024, the median was 6.7 months.
A quarter of the prison terms were 16.5 months or more. A quarter were 4 months or less. A mandatory minimum prison term applied to 0 of the 185 people.
Reading the Title of §2S1.3
The Guidelines Manual names §2S1.3 "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 classifies all 185 cases as Money Laundering.
Fiscal year 2025 ran from October 1, 2024 to September 30, 2025. The figures include people who were convicted and sentenced, with §2S1.3 as the primary guideline, meaning the guideline that set the offense level for the most serious count.
Pleas and Trial Convictions
182 people (98%) pleaded guilty. 3 were convicted after a trial. 87% of the guilty pleas had a written plea agreement, and 12% were straight pleas.
The median prison term after a guilty plea was 8 months, and after a trial it was 48 months. Only 3 people were convicted at trial and sent to prison, so the trial figure is not a reliable guide to trial cases overall.
Release Terms and Financial Penalties
130 people (70%) were ordered to serve supervised release after prison, with a median term of 36 months. A fine was ordered for 25 (14%). Restitution was ordered for 18 (10%).
91% were in the lowest criminal history category, and less than 1% in the highest. Court-martial records have no criminal history field, so that detail cannot be compared.
Comparison With All Federal Sentences
In fiscal year 2025, 66,662 people were sentenced under all guidelines. The median prison term was 24 months and 98% pleaded guilty. The median under §2S1.3 was lower.
Across fiscal years 2016 to 2025, 1,782 people were sentenced under §2S1.3. 75% went to prison, the median prison term was 10 months, and 41% were within the range. Fiscal year 2024 had 177 people. The table shows every year in the series.
| 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% |
What Cannot Be Concluded
The approved crosswalk lists no close court-martial counterpart, so this post gives federal numbers only. It may be too early to call the move in the median from 6.7 months to 8 months a pattern, and the records give no reason for it.
How We Counted
Everyone sentenced in federal court in fiscal year 2025 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 2024 (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.