- 11,503
In total, he structured 71 cash deposits and withdrawals totaling $568,440 in two personal bank accounts and 297 ATM deposits and withdrawals totaling $277,450 in a Merrill account, according to the complaint.
Iannazzo structured the cash transactions to "avoid conducting a single deposit or withdrawal over $10,000 at a financial institution, which would require the financial institution to file a CTR," FINRA alleged.
Yeah... that's a justified investigation. I could see it 1-2 times... but not 71. And it's not like he didn't know about AML and structuring.