Cite as: 510 U. S. 135 (1994)
Blackmun, J., dissenting
II
Although I believe the statutory language is clear in light of our precedents, the legislative history confirms that Congress intended to require knowledge of (and a purpose to evade) the reporting requirements but not specific knowledge of the illegality of structuring.9
Before 1986, the reporting requirements included no provision explicitly prohibiting the structuring of transactions to evade the reporting requirements. The Government attempted to combat purposeful evasion of the reporting requirements through 18 U. S. C. § 1001, which applies to anyone who "knowingly and willfully falsifies, conceals or covers up by any trick, scheme, or device a material fact" within the jurisdiction of a federal agency, and 18 U. S. C. § 2(b), which applies to anyone who "willfully causes an act to be done which if directly performed by him or another would be an offense" under federal law. Some Courts of Appeals upheld application of those criminal statutes where a report would have been filed but for the defendant's purposeful structuring. See, e. g., United States v. Tobon-Builes, 706 F. 2d 1092, 1096-1101 (CA11 1983); United States v. Heyman, 794 F. 2d 788, 790-793 (CA2), cert. denied, 479 U. S. 989 (1986). As the leading case explained, a defendant's willfulness was established if he "knew about the currency reporting requirements and . . . purposely sought to prevent the financial institutions from filing required reports . . . by structuring his transactions as multiple smaller transactions under $10,000." Tobon-Builes, 706 F. 2d, at 1101.
Other courts rejected imposition of criminal liability for structuring under §§ 1001 and 2(b), concluding either that the
9 Because the statutory language unambiguously imposes no requirement of knowledge of the illegality of structuring, I would not apply the rule of lenity. Moreover, I am not persuaded that that rule should be applied to defeat a congressional purpose that is as clear as that evidenced here. See Liparota, 471 U. S., at 427; United States v. Bramblett, 348 U. S. 503, 509-510 (1955).
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