According to FINRA, James Anthony Iannazzo has been fined $50,000 and suspended from association with any FINRA member in all capacities for two years for structuring cash withdrawals and deposits totaling $845,890 with knowledge of, and intent to evade, federal currency reporting requirements. This decision has been appealed to the National Adjudicatory Council.

Iannazzo repeatedly obtained more than $10,000 in cash by withdrawing between $8,000 and $9,500 from a joint checking account and, on the same day, withdrawing the daily maximum of $2,500 from a separate account at another financial institution using an ATM. This pattern avoided triggering currency transaction report (CTR) requirements for transactions exceeding $10,000.

On many occasions, Iannazzo withdrew or deposited tens of thousands of dollars in cash within days or weeks while avoiding any single transaction exceeding $10,000 at the same financial institution. He never engaged in cash transactions exceeding $10,000 at the same institution on any one day.

This pattern continued over approximately six years.

Structuring is a federal crime because currency transaction reports are essential tools for detecting money laundering, tax evasion, and other financial crimes. When individuals deliberately break up transactions to avoid reporting requirements, they undermine these protections.

For investors, a representative's involvement in structuring raises serious concerns about their integrity and judgment. While this conduct may not directly involve customer accounts, it demonstrates a willingness to evade legal requirements that is inconsistent with the obligations of a securities professional.

The case is currently on appeal, and the sanctions are not in effect pending review. The National Adjudicatory Council may modify the findings or sanctions.