New York, NY, USA – March 9, 2016: TD Bank: Toronto-Dominion Bank is a Canadian multinational banking and financial services company headquartered in Toronto.
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On July 15, Wilfredo Aquino, a former assistant manager of TD Bank’s Midtown Manhattan branch, was sentenced to 46 months in prison for enabling a money laundering network to move hundreds of millions of dollars through TD Bank accounts.
“The defendant took advantage of his position at TD Bank and facilitated the criminal activities of a money laundering network that moved hundreds of millions of dollars through the bank’s accounts,” said Assistant Attorney General A. Tysen Duva of the Justice Department’s Criminal Division. “During the illegal scheme, the defendant evaded reporting requirements to conceal the identity of the leader of the money laundering network.”
“Because of his position at TD Bank, Wilfredo Aquino was required to report suspicious customer activity and comply with strict anti-money laundering regulations,” said Special Agent in Charge Jenifer L. Piovesan of the IRS Criminal Investigation (IRS-CI) Newark Field Office.
From 2019 to February 2021, Aquino enabled a money laundering network to move hundreds of millions of dollars through TD bank accounts. During this time, the network’s leader, Da Ying Sze, also known as David, and his co-conspirators transferred approximately $474 million through TD Bank accounts by depositing cash at TD Bank branches in New York, New Jersey and elsewhere. In February 2022, Sze pleaded guilty to coordinating a $653 million money laundering conspiracy, operating an unlicensed money transfer business, and bribing bank employees in connection with financial transactions.
Aquino processed around 1,680 official bank checks for Sze’s Network, totaling more than $92 million. Almost all of these cashier’s checks were funded by cash deposits of more than $10,000, triggering TD Bank’s legal requirement to file a Currency Transaction Report (CTR). Although Aquino knew that Sze made these cash deposits, Aquino never identified Sze as a “conductor” in the CTR. Aquino also knew that TD Bank had closed other accounts linked to Sze because of suspicious activity; A colleague even warned Aquino that Sze’s activities “look like money laundering.” In February 2021, Aquino facilitated three money laundering transactions by Sze, totaling nearly $2 million in cash, into a third-party account and failed to report Sze as the leader of the transaction, thereby concealing Sze’s role in the money laundering scheme.
In return for his help, Aquino received gift cards from Sze totaling over $11,000.
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TD Bank money laundering settlement
In 2024, TD Bank pleaded guilty to both civil and criminal charges, including conspiracy to violate the Bank Secrecy Act related to money laundering. As a condition of the settlement, TD Bank paid a penalty of $1.8 billion, which, when combined with civil penalties, brought the total to $3 billion. TD Bank’s settlement also required the bank to fundamentally restructure its anti-money laundering compliance program, which it did in significant ways to prevent the kinds of violations that Aquino committed. In particular, Aquino was able to hide suspicious cash activity and circumvent the requirement for a currency transaction report by assisting criminal networks in their money laundering.
TD Bank response
TD Bank has invested more than $1 billion in enhanced anti-money laundering measures, including implementing enhanced transaction monitoring systems by using machine learning AI tools to detect suspicious activity such as layering and unusual cross-border transactions. Layering occurs when money is moved across multiple transactions to hide the origin of the funds. TD Bank has also enhanced its Customer Due Diligence and Know Your Customers verification processes through enhanced risk profiling and ongoing monitoring of high-risk customers. In addition, the bank has expanded its anti-money laundering training programs for its employees and introduced a stronger compliance culture that emphasizes increased attention to the risks of financial crime.
https://www.forbes.com/sites/steveweisman/2026/07/18/money-laundering-bank-manager-sentenced-as-bank-overhauls-aml-compliance/
