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FINRA Disciplinary Action: David A. Dodson Suspended for Structured Cash Deposits

2024-03-22

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According to FINRA, David A. Dodson (CRD #2363957) of Brookhaven, Georgia, was suspended for 20 months and assessed a deferred fine of $10,000 for intentionally making structured cash deposits to avoid federal Currency Transaction Report (CTR) reporting requirements. The action, effective March 22, 2024, found that Dodson made structured cash deposits totaling $248,460 across two bank accounts, deliberately keeping individual deposit amounts below $10,000 to circumvent the CTR reporting threshold. Notably, these deposits did not involve customer funds; rather, they were Dodson's personal transactions. The investigation established that Dodson had knowledge of CTR requirements, having received Bank Secrecy Act (BSA) training through his member firm. The structuring of financial transactions to evade CTR reporting requirements is a federal offense under 31 U.S.C. Section 5324. Financial institutions are required to file CTRs with the Financial Crimes Enforcement Network (FinCEN) for cash transactions exceeding $10,000. This reporting framework is a critical component of the nation's anti-money laundering (AML) infrastructure, designed to detect and prevent financial crimes including money laundering, tax evasion, and terrorist financing. Deliberately breaking up cash transactions into smaller amounts to avoid these reporting thresholds, known as "structuring," is illegal regardless of whether the underlying funds are derived from legitimate sources. Dodson's conduct also violated FINRA Rule 2010, which requires associated persons to observe high standards of commercial honor and just and equitable principles of trade. A registered representative who engages in structuring demonstrates a willingness to evade federal law, which is fundamentally incompatible with the trust that investors and regulators place in financial professionals. Dodson's suspension is effective from April 1, 2024, through November 30, 2025. This case serves as a stark reminder that financial professionals are held to high standards of legal compliance in all aspects of their financial dealings, not just their client-facing activities. Investors should be aware that structured transactions by their financial professionals may indicate broader compliance issues. FINRA Case #2022075762601 provides further details on this matter.

Violation :

Intentional structuring of cash deposits to avoid federal Currency Transaction Report reporting requirements

Tags :

David A. Dodson,
GA
CRD Number : 2363957

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