156
Blackmun, J., dissenting
any event, Congress has determined that purposefully structuring transactions is not innocent conduct.7
In interpreting federal criminal tax statutes, this Court has defined the term "willfully" as requiring the " 'voluntary, intentional violation of a known legal duty.' " Cheek v. United States, 498 U. S., at 200, quoting United States v. Bishop, 412 U. S. 346, 360 (1973); see also United States v. Murdock, 290 U. S. 389, 394-396 (1933). Our rule in the tax area, however, is an "exception to the traditional rule," applied "largely due to the complexity of the tax laws." Cheek, 498 U. S., at 200; see also Browder v. United States, 312 U. S., at 341-342. The rule is inapplicable here, where, far from being complex, the provisions involved are perhaps among the simplest in the United States Code.8
as in Liparota, 471 U. S., at 426, and it would not justify reading into the statute a knowledge-of-illegality requirement.
7 "[The antistructuring provision] requires proof beyond a reasonable doubt that the purpose of the 'structured' aspect of a currency exchange was to evade the reporting requirements of the Bank Secrecy Act. It is this requirement which shields innocent conduct from prosecution." Hearing on S. 571 and S. 2306 before the Senate Committee on Banking, Housing, and Urban Affairs, 99th Cong., 2d Sess., 136-137 (1986) (response of Deputy Asst. Atty. Gen. Knapp and Asst. U. S. Atty. Sun to written question of Sen. D'Amato).
8 The majority offers examples of tax "avoidance" as further evidence of the apparent "innocence" of structuring transactions to evade the reporting requirements. See ante, at 145-146. These examples are inapposite because Congress specifically has prohibited the structuring of transactions to evade the reporting requirements. Indeed, its use of the word "evading" in § 5324 reveals that Congress deemed the intent to circumvent those requirements a "bad purpose." Moreover, the analogy to the tax field is flawed. Tax law involves a unique scheme consisting of myriad categories and thresholds, applied in yearly segments, designed to generate appropriate levels of taxation while also influencing behavior in various ways. Innocent "avoidance" is an established part of this scheme, and it does not operate to undermine the purposes of the tax law. In sharp contrast, evasion of the currency transaction reporting requirements completely deprives the Government of the information that those requirements are designed to obtain, and thus wholly undermines the purpose of the statute.
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