Cite as: 510 U. S. 135 (1994)
Blackmun, J., dissenting
ity of § 5322(a), which sets a single standard—willfulness— for the subchapter's various reporting provisions. Some of those provisions do not themselves define willful conduct, so the willfulness element cannot be deemed surplusage. Moreover, the fact that § 5322(a) requires willfulness for criminal liability to be imposed does not mean that each of the underlying offenses to which it applies must involve something less than willfulness. Thus, the fact that § 5324 does describe a "willful" offense, since it already requires "the purpose of evading the reporting requirements," provides no basis for imposing an artificially heightened scienter requirement.
The majority also contends that § 5322(a)'s willfulness element, when applied to the subchapter's other provisions, has been read by the Courts of Appeals to require knowledge of and a purpose to disobey the law. See ante, at 141-142. In fact, the cases to which the majority refers stand for the more subtle proposition that a willful violation requires knowledge of the pertinent reporting requirements and a purpose to avoid compliance with them.4 Consistent with and in light
4 The dominant formulation of the standard for a willful violation of the related provisions demands "proof of the defendant's knowledge of the reporting requirement and his specific intent to commit the crime." United States v. Granda, 565 F. 2d 922, 926 (CA5 1978); see also United States v. Bank of New England, N. A., 821 F. 2d 844, 854 (CA1) ("willful" violation of § 5313 requires " 'knowledge of the reporting requirements and [defendant's] specific intent to commit the crime' "), cert. denied, 484 U. S. 943 (1987); United States v. Eisenstein, 731 F. 2d 1540, 1543 (CA11 1984) (same); United States v. Dichne, 612 F. 2d 632, 636 (CA2 1979) (same standard under predecessor to § 5316), cert. denied, 445 U. S. 928 (1980); United States v. Schnaiderman, 568 F. 2d 1208, 1211 (CA5 1978) (same). The term "specific intent" does not, as the majority appears to assume, import the notion of knowledge of illegality. Rather, that term generally corresponds to the concept of "purpose," see United States v. Bailey, 444 U. S. 394, 405 (1980), and it does not add to the requisite knowledge, which is specified in the first prong of the standard. The majority correctly notes that courts in a few instances have referred to a willful violation of the reporting provisions as involving violation of a "known legal duty." Those courts, however, either applied the standard from Cheek v. United
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