Compliance Brief - July 22, 2026 - Global RADAR
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Compliance Brief – July 22, 2026

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Edition 9 · July 22, 2026

In This Edition

TD insiders sentenced: 46 months, $474M

What’s new in compliance. Why it matters. What it means for your operations.

This is Edition 9 of your Weekly Compliance Brief, Wednesday, July 22, 2026.

From the Founder
The TD sentencings settle a question boards keep asking: yes, individuals go to prison. An assistant manager took $11,000 in gifts and got 46 months. Your frontline staff are a control surface, and your board should see your insider-risk monitoring before a prosecutor describes it. Ask this week: who watches the watchers?
Dominic Suszek · Founder and CEO, Global RADAR

This Week in 30 Seconds

  • Two TD Bank insiders sentenced July 16; 46 and 24 months in prison
  • Iran relief fully unwound; General License X expired July 17
  • Federal Reserve proposes AML program overhaul; comments due September 8

1. Top story of the week

Individual accountability arrived this week: two former TD Bank insiders were sentenced to prison on July 16. Wilfredo Aquino, a former assistant manager, received 46 months for helping a network move funds in a $474 million laundering scheme, processing over $92 million in checks in exchange for roughly $11,000 in gifts. Edward Low received 24 months for wire fraud conspiracy and false bank entries. The sentencings follow TD’s $3 billion resolution.

Why This Matters

DOJ moved from the institution’s $3 billion penalty to the employees who ran the facilitation. Frontline staff who override controls now face prison, not just termination, and the conduct at issue ran for years inside a supervised institution before anyone stopped it.

Operational Implications

Three steps for this week:

  1. Brief branch and operations managers on the Aquino case this week; the $11,000-in-gifts detail lands in a way policy training does not.
  2. Pull override and exception reports for your highest-cash locations by month-end and document the review; insider cases surface in exactly these records.
  3. Add insider facilitation to your enterprise risk assessment this quarter; we think most programs still file it under HR, and examiners have stopped agreeing.

2. Enforcement and penalties

  • OFAC, July 17: General License X wind-down expired; Iran oil relief is fully unwound, leaving only General License Z through September 12.
  • OFAC, July 17: Moved Hong Kong Autonomy Act names from the SDN List to the Non-SDN Menu-Based Sanctions List; earlier blocks remain in effect.
  • OFAC, July 15: Designated seven individuals and entities in an IRGC weapons procurement network across multiple jurisdictions.
  • OCC, July: Cease and desist order against United Texas Bank for BSA/AML program deficiencies resulting in violations of law.
Why This Matters

The July 17 action moved sanctioned names off the SDN List while keeping them sanctioned. Screening configured against SDN-only feeds will silently drop live Hong Kong risk, and that gap will not announce itself until an examiner or a payment does.

Operational Implications

Two moves this week:

  1. Confirm with your screening vendor this week that the Non-SDN Menu-Based Sanctions List is in your match set; we think the July 17 migration is the sleeper risk of the month.
  2. Re-run Hong Kong and mainland China counterparties against both lists and document the delta in your screening file by July 31.

3. New guidance and rulemaking

  • Federal Reserve, comments due September 8: Proposed rule modernizing AML/CFT program requirements for Board-supervised banks, completing the set of agency proposals begun by FinCEN in April.
  • FinCEN, July: Updated Section 314(b) fact sheet clarifies voluntary information sharing covers fraud; OCC circulated the guidance to national banks.
Why This Matters

With the Fed’s proposal, every federal banking agency plus FinCEN now has an AML modernization rule in flight, all pointing toward risk-based programs with explicit board accountability. The comment windows are where thresholds and expectations get set for the next decade.

Operational Implications

Two assignments before month-end:

  1. Assign one owner to draft your Fed comment by August 14; institutions that stay silent get rules written by their largest competitors.
  2. Brief your fraud team on the updated 314(b) fact sheet this week and document in procedure whether fraud referrals now route through sharing agreements.
Theme of the Week
Enforcement is shifting from institutions to individuals. TD paid $3 billion; this week its former employees drew 46 and 24 months, and $11,000 in gifts was enough to buy a channel that moved $474 million. Compliance programs that monitor customers but not employees are watching the wrong door. Insider facilitation is an AML control domain, not an HR file.

4. Global watch

  • AMLA, July 2: Proposed common EU standards for reporting suspicious transactions; consultation underway.
  • HM Treasury, July: Updated high-risk third country advisory after June FATF plenary list changes.
  • FATF, July: Virtual assets update warns crime groups move billions through crypto gaps.
  • AUSTRAC, deadline July 29: Tranche 2 enrolment closes; daily penalties follow for unregistered entities.

5. Coming up in the next 30 days

Date Event or deadline
July 27, 2026 FinCEN Section 311 proposal on Huione Pay closes for comment.
July 29, 2026 AUSTRAC Tranche 2 enrolment deadline; daily penalties begin for unregistered entities.
August 4, 2026 Comments close on the FDIC GENIUS Act AML and CFT rule for stablecoin issuers.
August 21, 2026 Comments close on the FinCEN and OCC stablecoin Customer Identification Program proposal.
September 8, 2026 Comments close on the Federal Reserve AML/CFT program modernization proposal.
September 12, 2026 General License Z wind-down expires for the July 14 Shamkhani network designations.

Next Wednesday

AUSTRAC’s enrolment deadline and the Huione Pay comment window will both have closed; we will cover the fallout, plus early industry reaction to the Fed’s AML proposal.

Want a 30-minute review of your employee-activity monitoring and insider-risk controls against the TD case fact pattern? Book a call with a Global RADAR compliance specialist.

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