from the structuring offense itself. Redefining the Bank Secrecy Act: Currency Reporting and the Crime of Structuring, 50 Santa Clara L.Rev. 407, 486 (2010). For example, structuring is separate from income tax evasion when the defendant structures a series of deposits to avoid paying income taxes. Id. Second, the enhancement applies when the defendant engages in what has been coined as “ ‘serial structuring.’ ” Id. Serial structuring refers to a pattern of structuring activity involving more than $100,000.00 in any twelvemonth period, and applies “even in the absence of other criminal activity.” Id. Typically, serial structuring involves a series of related currency transaction report violations. See, e.g., United States v. St. Michael’s Credit Union, 880 F.2d 579, 587 (1st Cir.1989) (<HOLDING>). Finally, the pattern of unlawful activity
holding termination wrongful when employee had a statutory duty to report violations recognizing step transaction doctrine whereby courts must consider all steps of transaction in light of entire transaction so that substance of transaction will control over form of each step holding that to establish a pattern of unlawful activity in a ease involving currency transaction report violations the government must prove that the currency transaction report violations were both repeated and related to one another holding invalid forfeiture of 357000 for failing to report exported currency affecting only  the government and in a relatively minor way holding that sale of two obscene magazines to one detective in one transaction and sale of two obscene films to another detective in another transaction could result in only one conviction for each separate transaction