Lordianto v Commissioner of the Australian Federal Police

Funds deposited into a person's bank account in 'structured' amounts (below the $10,000 reporting threshold) are 'proceeds' of the offence of structuring under the Proceeds of Crime Act 2002 (Cth) and may be forfeited, and an innocent recipient who is a victim of 'cuckoo-smurfing' cannot establish the s 330(4)(a) third-party exclusion where there is no relevant connection between the acquisition and sufficient consideration provided to the offender.