TD Bank Insider Guilty Plea Exposes Deep AML Control Failures

A former TD Bank employee has pleaded guilty to facilitating one of the largest insider-enabled money laundering schemes prosecuted in recent years, exposing serious weaknesses in frontline controls, insider risk management and transaction reporting frameworks at large retail banks.

On 6 January 2026, Wilfredo Aquino, a former assistant store manager at TD Bank N A, admitted to conspiring to launder monetary instruments while employed at the bank. Between 2019 and February 2021, Aquino used his position at a Midtown Manhattan branch to support a sophisticated money laundering network that moved approximately $474 million in cash through TD Bank accounts.

According to court filings, the network was led by Da Ying Sze, also known as David, who pleaded guilty in February 2022 to coordinating a $653 million money laundering conspiracy, operating an unlicensed money transmitting business and bribing bank employees. While the network operated across multiple TD Bank locations in New York, New Jersey and elsewhere, the bulk of the activity was concentrated at Aquino’s branch, where he processed more transactions for the network than any other employee.

The scheme relied heavily on cash deposits used to fund official bank cheques. Aquino processed approximately 1,680 bank cheques totalling more than $92 million, almost all funded by cash deposits exceeding $10,000. These transactions triggered mandatory Currency Transaction Report (CTR) filing requirements. Despite knowing that David was the true conductor of the transactions, Aquino repeatedly failed to identify him on CTR filings, deliberately concealing the network leader’s involvement.

Aquino also facilitated transactions after TD Bank had already closed other accounts linked to David for suspicious activity. In one instance, a colleague explicitly warned Aquino that the activity “looks like money laundering”. In February 2021, Aquino processed nearly $2 million in cash transactions through a third party account while again omitting David as the conductor, further obstructing regulatory visibility.

In return for his assistance, Aquino accepted retail gift cards worth more than $11,000. He has now pleaded guilty to a single count of conspiracy to launder monetary instruments, which carries a maximum sentence of 20 years’ imprisonment and significant financial penalties. Sentencing is scheduled for 12 May 2026.

For financial institutions, this case is a stark reminder that insider risk remains one of the most acute and under-managed threats to anti-money laundering frameworks. Policies, monitoring systems and automated alerts are ineffective where staff are able to override controls, falsify reporting or deliberately misrepresent transaction conductors without timely detection.

The prosecution also reinforces the regulatory expectation that bank employees are a critical first line of defence. Failures to escalate suspicions, accurately complete CTRs and respond to known red flags can quickly escalate from compliance breaches into criminal liability. The involvement of IRS Criminal Investigation and the FDIC Office of Inspector General further underlines the seriousness with which US authorities treat insider-enabled financial crime.

As enforcement agencies continue to prioritise bank integrity cases, institutions should expect increased scrutiny of employee behaviour, branch-level cash activity and the robustness of internal escalation and surveillance mechanisms. This case illustrates that AML risk is not only external. It can be embedded deep within trusted operational roles if governance, culture and accountability are weak.

Read the press release here.