- Important insight: As part of the continued prosecution of a large-scale money laundering operation at TD Bank, a federal judge imposed sentences of 46 and 24 months, respectively.
- Expert quote: “This could be a great outcome for the senior TD people who would continue to be in the DOJ’s sights.” – James Richards, former Wells Fargo BSA officer
- What’s at stake: The Toronto-based bank paid more than $3 billion in penalties after pleading guilty to federal charges. It continues to work on mandatory AML remediation.
Two former middle management employees at TD Bank received prison sentences for their roles in a massive, multi-year money laundering scheme that cost the bank more than $3 billion in federal penalties and led to a significant reduction in its U.S. operations.
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Wilfredo Aquino — a former deputy manager who enabled a money laundering network to transfer nearly half a billion dollars through TD accounts — was sentenced last week to 46 months in federal prison. A co-conspirator, Edward Low, was sentenced to 24 months in prison for his involvement.
According to the U.S. Department of Justice, the money laundering operation was led by Da Ying “David” Sze, whose network moved approximately $474 million through TD accounts by depositing cash at branches in New York, New Jersey and elsewhere.
From 2019 to 2021, Aquino processed 1,680 official bank checks totaling more than $92 million for Sze’s network in exchange for gift cards worth over $11,000. He pleaded guilty to money laundering conspiracy in January 2026.
Low, a former retail employee in Flushing, Queens, accepted $26,700 in bribes to steal and share sensitive customer information with the criminal network, which then withdrew $485,000 from customer accounts. In February 2026, Low pleaded guilty to conspiracy to commit wire fraud at a financial institution and making false bank entries or reports as a bank teller.
In October 2024, TD entered into a historic criminal penalty agreement and a separate civil settlement with federal regulators for systemic violations of the Bank Secrecy Act. The Toronto-based bank agreed to pay a total of more than $3 billion in penalties and its U.S. assets were capped indefinitely at about $434 billion.
Under the terms of the settlement, TD was required to implement enhanced transaction monitoring, improve customer due diligence procedures and improve employee AML training. In particular, regulators pointed to failures in identifying structured, cash-intensive activities and high-risk customer profiles.
Anti-money laundering cleanup “remains a top priority for the bank,” a TD Bank spokesman wrote in a statement to American Banker on Monday. “TD has made great progress in rebuilding its AML program, including through significant investments in talent, training, process improvements and technology.”
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The Trump Administration’s Enforcement of White Collar Crimes
James Richards, who served as Wells Fargo’s bank secrecy officer and head of its financial crimes risk management group for more than a decade, told American Banker that authorities had “aggressively, aggressively pursued” the TD Bank cases.
He added that the speed of the trials and certain other methods in which the cases were handled showed that the government was “very interested in seeing these people prosecuted, and prosecuted hard and fast.”
Although no TD executives were prosecuted, Richards said the convictions of mid-level employees appeared to have “satisfied the DOJ.”
“This could be a great outcome for the senior TD people who would continue to be in the DOJ’s sights,” Richards said.
He compared the handling of the TD Bank case to other recent high-profile white-collar cases in which defendants have received more leniency from federal actors.
While prominent white-collar criminals often receive cheaper compensation, Aquino, Low and their co-conspirators “had nothing to offer the government, nothing they could exchange for a lenient sentence,” Richards said.
He compared the TD prosecution to the government’s criminal case against former Binance CEO Changpeng “CZ” Zhao.
In 2023, Zhao was sentenced to four months in federal prison for anti-money laundering and U.S. sanctions violations, including approving transactions with terrorist and drug trafficking groups. Zhao received a full pardon from President Donald Trump in October 2025.
“When you compare it to CZ, you’re like, what the hell is going on?” Richards said.
According to Justice Department records, Trump issued more than 1,400 pardons and commutations in his second term alone – six times more than the 238 he granted in his entire first term. Those pardoned include well-known financial criminals, including Zhao and Silk Road founder Ross Ulbricht.
In June, convicted FTX founder Sam Bankman-Fried requested a presidential pardon, three years into his 25-year prison sentence for the $10 billion fraud he orchestrated through his cryptocurrency empire. Last week, the Senate unanimously passed a resolution saying Bankman-Fried should not receive a pardon.
“I cannot imagine any administration that has abused prosecutorial discretion over who and why to prosecute and the president’s pardon power,” Richards said. “The combination of the two may be unprecedented. And I don’t believe it serves the long-term common good.”
https://www.americanbanker.com/news/ex-td-bank-employees-sentenced-in-money-laundering-scheme
