Cite as: 510 U. S. 135 (1994)
Opinion of the Court
should be heightened when the words describe an element of a criminal offense. See Pennsylvania Dept. of Public Welfare v. Davenport, 495 U. S. 552, 562 (1990) (expressing "deep reluctance" to interpret statutory provisions "so as to render superfluous other provisions in the same enactment") (citation omitted); cf. Potter v. United States, 155 U. S. 438, 446 (1894) (word "wilful" used to describe certain offenses but not others in same statute "cannot be regarded as mere surplusage; it means something").
"Willful," this Court has recognized, is a "word of many meanings," and "its construction [is] often . . . influenced by its context." Spies v. United States, 317 U. S. 492, 497 (1943). Accordingly, we view §§ 5322(a) and 5324(3) mindful of the complex of provisions in which they are embedded. In this light, we count it significant that § 5322(a)'s omnibus "willfulness" requirement, when applied to other provisions in the same subchapter, consistently has been read by the Courts of Appeals to require both "knowledge of the reporting requirement" and a "specific intent to commit the crime," i. e., "a purpose to disobey the law." See United States v. Bank of New England, N. A., 821 F. 2d 844, 854-859 (CA1 1987) ("willful violation" of § 5313's reporting requirement for cash transactions over $10,000 requires "voluntary, intentional, and bad purpose to disobey the law"); United States v. Eisenstein, 731 F. 2d 1540, 1543 (CA11 1984) ("willful violation" of § 5313's reporting requirement for cash transactions over $10,000 requires " 'proof of the defendant's knowledge of the reporting requirement and his specific intent to commit the crime' ") (quoting United States v. Granda, 565 F. 2d 922, 926 (CA5 1978)).
Notable in this regard are 31 U. S. C. § 5314,8 concerning
records and reports on monetary transactions with foreign
8 Section 5314 provides that "the Secretary of the Treasury shall require a resident or citizen of the United States or a person in, and doing business in, the United States, to keep records, file reports, or keep records and file reports, when the resident, citizen, or person makes a transaction or maintains a relation for any person with a foreign financial agency."
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