TD Bank Insiders Jailed for Enabling Money Laundering & Fraud

Two former employees of TD Bank, N.A. have been sentenced to prison in the US for their roles in enabling money laundering and fraud from within the institution, in cases prosecuted by the Department of Justice (DOJ). The outcomes are a pointed reminder that the control environment is only ever as strong as the people operating it.

Wilfredo Aquino, an assistant store manager, received 46 months after admitting he conspired to launder monetary instruments. Between 2019 and February 2021 he used his position to help a network led by Da Ying Sze, known as David, move around $474 million through TD Bank accounts. Aquino processed approximately 1,680 official bank checks worth more than $92 million, nearly all funded by cash deposits above $10,000. Each of those deposits triggered the requirement to file a currency transaction report (CTR), yet Aquino never named David as the conductor of the transactions, deliberately obscuring his role. He did so despite a colleague warning that the activity "looks like money laundering", and despite knowing other accounts linked to David had been closed for suspicious activity. In return he accepted more than $11,000 in retail gift cards.

Edward Low, a retail employee, was sentenced to 24 months for conspiring to commit wire fraud affecting a financial institution and making false bank entries. Low accepted bribes to extract confidential customer information, which co-conspirators used to take over accounts and steal funds, facilitating $484,572.16 in fraud at TD Bank. After moving to a second institution, he took a further bribe to falsify records and open a shell company account used for additional fraud. In total he received at least $26,700 in bribes.

The cases were investigated by the Internal Revenue Service Criminal Investigation (IRS-CI) Newark Field Office and the Federal Deposit Insurance Corporation Office of Inspector General (FDIC OIG) New York Region.

For UK compliance teams, the lessons translate directly. Both individuals defeated automated controls not by breaking them but by manipulating the manual judgement points around them, above all the accurate recording of who is actually conducting a transaction. Under the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002, the integrity of customer due diligence and transaction monitoring depends on frontline staff entering truthful information. Where a trusted employee is compromised, threshold-based reporting and know-your-customer checks can be quietly hollowed out.

Three points stand out. First, colleague suspicion was present and voiced in the Aquino case but did not translate into escalation, underlining the value of confidential internal reporting routes that staff trust and use. Second, patterns such as repeated sub-relationship cash structuring and unnamed conductors are detectable through targeted assurance testing rather than system alerts alone. Third, insider risk should be treated as a distinct threat within the financial crime framework, with detective controls, dual authorisation and periodic conduct review applied to staff who hold the keys to reporting decisions.

The cases show that people risk sits alongside customer risk, and that the two are not always separable.

Read the press release here.