## Facts

- Waldemar Ratzlaf incurred a $160,000 gambling debt at a Nevada casino and attempted to pay part of it with $100,000 in cash.
- A casino official told him that cash transactions over $10,000 would be reported to authorities, but suggested that cashier’s checks would not trigger the same reporting.
- Ratzlaf went to multiple banks and bought cashier’s checks in amounts under $10,000 at different institutions, then used them to pay the casino.
- The government charged him with structuring transactions to evade the banks’ reporting obligations under the Bank Secrecy Act.
- At trial, the jury was instructed that the government needed to prove Ratzlaf knew of the banks’ duty to report cash transactions over $10,000 and intended to evade that duty, but did not need to prove he knew structuring itself was unlawful.

## Issues

1. Whether, to prove a “willful” violation of the antistructuring statute under 31 U.S.C. §§ 5322(a) and 5324, the government must show the defendant knew structuring was illegal.
2. Whether it is sufficient to prove only that the defendant knew of the reporting requirement and acted with the purpose of evading it.

## Decision

- The Supreme Court reversed the Ninth Circuit in a 5–4 decision and remanded.
- The Court held that the “willfully” requirement in § 5322(a) requires proof beyond a reasonable doubt that the defendant knew structuring to evade reporting was unlawful.
- Proof that the defendant knew of the reporting requirement and intended to avoid triggering it was not enough to sustain a conviction for a “willful” antistructuring violation.

## Legal Principles

- When a criminal statute requires a defendant to act “willfully,” the term may require knowledge that the conduct is unlawful, not merely intentional conduct with awareness of relevant facts.
- Where Congress uses a single omnibus “willfulness” clause to supply mens rea across a group of related regulatory offenses, the clause should be construed consistently absent clear contrary indications.
- The “purpose of evading” element in the antistructuring provision cannot, by itself, satisfy an additional “willfulness” requirement without rendering “willfully” redundant.
- Structuring cash transactions is not inherently wrongful in all circumstances; therefore, courts should not presume knowledge of illegality from the act of structuring alone.
- If statutory ambiguity remains about the scope of criminal mens rea, the rule of lenity favors the narrower construction.

## Conclusion

The Court required the government, in prosecutions for “willfully” violating the Bank Secrecy Act’s antistructuring provision, to prove that the defendant knew structuring transactions to evade reporting requirements was illegal, not merely that the defendant intended to avoid the banks’ reporting obligations.


Ratzlaf v. United States, 510 U.S. 135 (1994)