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Opinion of the Court
pretation of "willfully" in two other contexts. In certain cases involving willful violations of the tax laws, we have concluded that the jury must find that the defendant was aware of the specific provision of the tax code that he was charged with violating. See, e. g., Cheek v. United States, 498 U. S. 192, 201 (1991).17 Similarly, in order to satisfy a willful violation in Ratzlaf, we concluded that the jury had to find that the defendant knew that his structuring of cash transactions to avoid a reporting requirement was unlawful. See 510 U. S., at 138, 149. Those cases, however, are readily distinguishable. Both the tax cases 18 and Ratzlaf 19 involved highly technical statutes that presented the danger of ensnaring individuals engaged in apparently innocent conduct.20 As a result, we held that these statutes
17 Even in tax cases, we have not always required this heightened mens rea. In United States v. Pomponio, 429 U. S. 10 (1976) (per curiam), for example, the jury was instructed that a willful act is one done "with [the] bad purpose either to disobey or to disregard the law." Id., at 11. We approved of this instruction, concluding that "[t]he trial judge . . . adequately instructed the jury on willfulness." Id., at 13.
18 As we stated in Cheek v. United States, 498 U. S. 192, 199-200 (1991): "The proliferation of statutes and regulations has sometimes made it difficult for the average citizen to know and comprehend the extent of the duties and obligations imposed by the tax laws. Congress has accordingly softened the impact of the common-law presumption by making specific intent to violate the law an element of certain federal criminal tax offenses. Thus, the Court almost 60 years ago interpreted the statutory term 'willfully' as used in the federal criminal tax statutes as carving out an exception to the traditional rule [that every person is presumed to know the law]. This special treatment of criminal tax offenses is largely due to the complexity of the tax laws."
19 See Bates v. United States, 522 U. S. 23, 31, n. 6 (1997) (noting that Ratzlaf's holding was based on the "particular statutory context of currency structuring"); Ratzlaf, 510 U. S., at 149 (Court's holding based on "particular contex[t]" of currency structuring statute).
20 Id., at 144-145 ("[C]urrency structuring is not inevitably nefarious. . . . Nor is a person who structures a currency transaction invariably motivated by a desire to keep the Government in the dark"; Government's construction of the statute would criminalize apparently innocent activity); Cheek, 498 U. S., at 205 ("[I]n 'our complex tax system, uncertainty
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