← Broker database 2026-01-29
Christian Gonzalez Suspended for Structuring Cash Deposits to Evade Federal Reporting Requirements
According to FINRA, Christian Gonzalez was assessed a deferred fine of $5,000 and suspended from association with any FINRA member firm in all capacities for 12 months, effective February 2, 2026 through February 1, 2027, for making a series of cash deposits structured specifically to avoid triggering federal currency transaction reporting requirements—a practice known as structuring.FINRA found that Gonzalez made cash deposits in a firm account totaling $58,970, with each individual deposit in an amount deliberately kept below the $10,000 threshold that triggers mandatory Currency Transaction Report (CTR) filing under the Bank Secrecy Act (BSA). Financial institutions, including broker-dealers, are required under the BSA to file CTRs for all cash transactions exceeding $10,000. Structuring—deliberately breaking up transactions to avoid the $10,000 reporting threshold—is itself a federal crime under 31 U.S.C. § 5324, separate from any other underlying illegal activity.FINRA found that Gonzalez had received Bank Secrecy Act training from his member firm specifically informing him that financial institutions are required to report cash transactions over $10,000 and that structuring is prohibited. Despite this training, he deliberately made deposits in sub-threshold amounts to evade reporting. The total amount deposited—$58,970—would have generated CTR filings if deposited in a single or fewer transactions, which appears to have been the motivation for breaking the amounts apart.Anti-money laundering laws and reporting requirements exist to help law enforcement detect and investigate money laundering, tax evasion, and other financial crimes. Structuring deprives regulators of visibility into potentially suspicious financial activity and can facilitate broader criminal conduct. The fact that Gonzalez received explicit training on BSA requirements makes this violation particularly serious.For investors, this case serves as a reminder that the securities industry is subject to robust anti-money laundering oversight, and that broker-dealers have legal obligations to detect and report suspicious financial transactions. Investors who observe suspicious cash handling by a broker or firm representative should report their concerns to the firm's compliance department, FINRA, or the Financial Crimes Enforcement Network (FinCEN).