Banking Officer Liability Materializes As TD Bank’s Money Laundering Fallout Continues
2025 was a whirlwind for Canadian-American TD Bank Group. The multinational banking giant was mired in the largest money laundering scandal of the decade, pleading guilty to both civil and criminal charges related to U.S. Bank Secrecy Act violations and having their widespread AML deficiencies across the international spectrum in the process. The investigations analyzed a nine-year span of rampant impropriety, during which time TD Bank failed to appropriately monitor a reported $18.3 trillion dollars of questionable customer activity.2 During their respective investigations, the U.S. Justice Department (DOJ), Financial Crimes Enforcement Network (FinCEN), and Office of the Comptroller of the Currency (OCC) discovered that TD’s American operations failed to implement adequate controls to detect and prevent money laundering in line with current national standards from 2014 through 2023.
These systemic violations ultimately culminated in TD facilitating nearly $700 million worth of illicit transactions on behalf of criminals operating both domestically and abroad – namely Chinese-backed crime groups and drug traffickers who were effectively using TD’s domestic branches as tools to launder the proceeds of U.S. fentanyl sales. During this period, organized criminal syndicates based in China had heavily subsidized fentanyl precursor materials, later supplying these to materials to Mexican drug cartels who would ultimately traffic the illicit drugs across the border and into the United States – further propelling the opioid epidemic seen across North America. With respect to these specific transgressions, one money laundering network processed more than $470 million through TD Bank via bulk cash deposits, many of which surpassed the $10,000 suspicious transaction reporting requirement currently maintained within the United States. In the rare event that suspicious transaction reports were ultimately filed by TD bank employees in these cases, they often failed to properly identify the conductor of the transaction within these documents, liberating the individuals behind this illicit activity from risk of prosecution.
As a result of their shortcomings, the firm received a $3+ billion-dollar collective penalty from the aforementioned regulators, while seeing additional restrictions placed on their U.S. asset growth. As part of the DOJ’s investigation however, the bank was also ordered to cooperate fully with more intricate investigations into the activities of their own officers, directors and employees in regard to these money laundering violations, where it was later discovered that multiple employees actively conspired to violate current U.S. AML/CFT regulations during this period. In the past Global RADAR has covered a shift towards increasing individual liability for corporate compliance failures, yet the actions taken against individual officers have remained few and far between to date. In these landmark proceedings however, prosecutors have not only resolved the bank’s liability but are also moving to separately charge individual bank staff found to have been complicit with this multinational laundering scheme. This series of actions began just last week.
On January 6th, Wilfredo Aquino, a 47-year-old former assistant manager at TD Bank in Midtown Manhattan, pleaded guilty to conspiring to launder monetary instruments on behalf of the above-mentioned illicit actors, becoming the first higher-level employee of TD Bank to be held responsible for the wide-scale money laundering occurring through the bank during this time period. Aquino’s actions reportedly facilitated the movement of hundreds of millions of dollars through the bank’s accounts as part of a broader money laundering network led by a Queens-based foreign operative named Da Ying Sze. The scheme in which Aquino was involved, which operated from 2019 to 2021, involved depositing large sums of cash and issuing official bank checks on behalf of Sze without proper reporting, evading anti-money laundering regulations.
According to court documents, Aquino processed approximately 1,680 bank checks totaling over $92 million for Sze’s criminal network, often funded by cash deposits exceeding $10,000 that triggered mandatory currency transaction reports (CTRs).1 Despite of advanced knowledge of Sze’s involvement in organized and white-collar crime (and even receiving warnings from colleagues about suspicious activity resembling money laundering), Aquino also failed to identify Sze as the conductor on these reports. In one instance in February 2021, Aquino reportedly handled three transactions amounting to nearly $2 million held in a third-party account, again concealing Sze’s role. In exchange for his assistance, Aquino received over $11,000 in retail gift cards from Sze.1 Sze himself pleaded guilty in February 2022 to coordinating a $653 million conspiracy, including operating an unlicensed money transmitting business and bribing TD Bank employees across various New York and New Jersey branches. Aquino’s respective branch processed the highest volume of these illicit transactions (reportedly amounting to a whopping $474 million), highlighting insider complicity in undermining the bank’s defenses against financial crimes.
“The defendant leveraged his position at TD Bank and facilitated the criminal activity of a money laundering network that moved hundreds of millions of dollars through the bank’s accounts,”2 said Assistant Attorney General A. Tysen Duva of the Justice Department’s Criminal Division. “During the illicit scheme, the defendant evaded reporting requirements to hide the identity of the leader of the money laundering network.”2
Aquino’s guilty plea carries a maximum penalty of 20 years in prison and a fine of $500,000 or twice the amount involved in the offense, whichever is greater.1 Sentencing is scheduled for May 12, 2026. The investigation into Aquino’s individual transgressions involved the IRS Criminal Investigation unit and the FDIC Office of Inspector General, with prosecutions handled by the DOJ’s Money Laundering and Asset Recovery Section. This landmark prosecution again points to the important role served by those on the front-lines of the ongoing international movement against illicit financial activity, with the ruling signaling a continued commitment to combating insider-facilitated money laundering, especially amid rising concerns over transnational criminal networks exploiting U.S. banks.
Citations
- “TD Bank Insider Pleads Guilty to Facilitating Money Laundering.” S. Department of Justice, Office of Public Affairs, 6 Jan. 2026,
- Weisman, Steve. “TD Bank and the Turning Point in Big Bank Money Laundering Enforcement.”Forbes, 9 Jan. 2026.