A hearing panel of the U.S. National Association of Securities Dealers announced today barred a Michigan-based rep, Christian Baker, from the securities industry for structuring currency transactions in to evade anti-money laundering currency-reporting requirements.

On July 10, 2001, NASD filed a complaint against Baker alleging, among other things, that she violated NASD rules by structuring currency transactions to evade federal reporting requirements. “It is imperative in today’s world that the front lines of our industry adhere to procedures that may help identify transactions that may have dubious origins,” said Mary Schapiro, NASD president of regulatory policy and oversight. “As this action illustrates, we will identify and sanction those in our industry who try to circumvent these procedures.”

In both the U.S. and Canada, financial institutions, including broker-dealers, are required to report cash transactions of more than $10,000 to the federal government. The requirements are aimed at disrupting possible money laundering, or terrorist financing.

In its decision, the NASD found that Baker accepted US$50,000 in cash from a customer who insisted that the transaction not be reported. After learning from a bank teller that reports were not required for cashier’s checks issued in amounts of less than US$3,000, Baker began to periodically exchange the customer’s cash for cashier’s checks in amounts of less than US$3,000. The panel found that over a four-month period, Baker purchased 24 separate cashier’s checks in amounts of less than US$3,000, eventually depositing the entire US$50,000 that was being held in her desk drawer into the customer’s account.

The panel also found that Baker did not record the receipt of the US$50,000 in cash, did not notify her employer or the U.S. Department of the Treasury that she had indeed received the cash, and failed to file the required report.