On July 15th Wilfredo Aquino, a former assistant manager at the Midtown Manhattan branch of TD Bank was sentenced to 46 months in prison for enabling a money laundering network’s movement of hundreds of millions of dollars through TD Bank accounts becoming the first TD Bank higher level employee to be held responsible for the massive money laundering done through the bank.
“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,” 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.”
“Wilfredo Aquino’s position at TD Bank required him to report suspicious customer activity and adhere to robust anti-money laundering regulations,” said Special Agent in Charge Jenifer L. Piovesan of the IRS Criminal Investigation (IRS-CI) Newark Field Office.
From 2019 until February 2021, Aquino facilitated a money laundering network’s movement of hundreds of millions of dollars through TD Bank accounts. During that time, the leader of the network, Da Ying Sze, also known as David, and his co-conspirators moved approximately $474 million through TD Bank accounts by depositing cash at TD Bank stores 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 transmitting business, and bribing bank employees in connection with financial transactions.
Aquino processed approximately 1,680 official bank checks for Sze’s Network, totaling more than $92 million. Nearly all these bank checks were funded through cash deposits exceeding $10,000, which triggered TD Bank’s legal requirement to file a Currency Transaction Report (CTR). Although Aquino knew that Sze was making these cash deposits, Aquino never identified Sze as the “conductor” on the CTR. Aquino also knew that TD Bank had closed other accounts linked to Sze for suspicious activity; one colleague even warned Aquino that Sze’s activity “looks like money laundering.” In February 2021, Aquino facilitated three of Sze’s money laundering transactions, totaling almost $2 million in cash, in a third party’s account and failed to report Sze as the conductor of the transaction, thereby concealing Sze’s role in the money laundering scheme.
In return for his assistance, Aquino received gift cards from Sze totaling over $11,000.
TD Bank Money Laundering Settlement
In 2024 TD Bank pled guilty to both civil and criminal charges including conspiring to violate the Bank Secrecy Act related to money laundering. As a condition of the settlement, TD Bank paid a $1.8 billion criminal penalty which when added to the civil fines 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 has done in a significant manner to prevent the type of violations Aquino committed. In particular, Aquino was able to conceal suspicious cash activity and avoid Currency Transaction Report requirements in his assistance of criminal networks in their money laundering.
TD Bank Response
TD Bank has invested more than a billion dollars in enhanced anti-money-laundering practices including the implementation of enhanced transaction monitoring systems through the use of machine-learning AI tools to recognize suspicious activity such as layering and unusual cross-border transactions. Layering occurs when money is moved through multiple transactions to hide the source of the funds. TD Bank also enhanced its Customer Due Diligence and Know Your Customers verification procedures with enhanced risk profiling and continual monitoring of high-risk customers. In addition, the bank increased its anti-money-laundering training programs for its employees, implementing a stronger compliance culture emphasizing increased alertness to financial crime risks.
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