A former TD Bank employee, identified as Aquino, has pleaded guilty to conspiring to launder monetary instruments, admitting to a role in a sophisticated money laundering network that moved hundreds of millions of dollars through the financial institution. The case sheds further light on the extensive anti-money laundering (AML) deficiencies that have plagued TD Bank, leading to significant regulatory scrutiny and substantial penalties. Aquino’s guilty plea, entered in January, is part of a broader Department of Justice (DOJ) investigation into TD Bank’s compliance failures.
The Scope of the Conspiracy
Court documents reveal that Aquino worked closely with Da Ying Sze, also known as David, a key figure in a money laundering network. Between 2019 and 2021, Sze and his associates are alleged to have funneled approximately $474 million through TD Bank accounts. This was primarily accomplished by depositing large sums of cash at various TD branches, with a significant concentration in New York and New Jersey.
The DOJ’s investigation into TD Bank’s AML weaknesses was reportedly ignited by the 2021 case against Sze. In February 2022, Sze pleaded guilty to orchestrating a $653 million money laundering conspiracy, operating an unlicensed money transmitting business, and bribing bank employees. This elaborate scheme was reportedly linked to the illicit sale of fentanyl, a potent synthetic opioid responsible for a significant portion of the ongoing opioid crisis in the United States.
A Pattern of Deficiencies
The fallout from Sze’s case and Aquino’s subsequent guilty plea underscores a systemic issue within TD Bank. According to the DOJ, the bank failed to adequately monitor a staggering $18.3 trillion in customer activity. This lapse allowed three distinct money laundering networks to move hundreds of millions of dollars through TD accounts undetected. The extent of these failures was detailed in an October 2024 report, which led to TD Bank agreeing to pay over $3 billion in penalties. In addition to the financial penalties, the bank’s U.S. retail bank assets were capped at $434 billion, a move designed to curb further risk exposure.
Aquino’s Direct Involvement
While multiple TD branches were implicated in the money laundering activities, the DOJ highlighted that Sze’s network laundered the largest sums through Aquino’s specific branch in Midtown Manhattan. Prosecutors stated in January that no individual processed more transactions for Sze’s network than Aquino. Evidence presented in court documents indicates a direct line of communication between Aquino and Sze, with the two periodically exchanging text messages concerning Sze’s account activity.
As part of the money laundering operation, Aquino processed approximately 1,680 official bank checks for Sze and his co-conspirators, totaling an estimated $92 million. A critical element of these transactions involved cash deposits exceeding $10,000, which legally required TD Bank to file Currency Transaction Reports (CTRs). However, the DOJ alleges that Aquino deliberately failed to identify Sze as the "conductor" of these deposits on the required reports, despite knowing Sze was actively involved in facilitating them.
Ignoring Red Flags
The prosecution presented evidence suggesting that Aquino was aware of the bank’s internal concerns regarding Sze’s activities. It was revealed that TD Bank had previously closed other accounts linked to Sze due to suspicious activity. Furthermore, a colleague had reportedly warned Aquino that Sze’s transactions "looks like money laundering," a clear indication that red flags were being raised internally. Despite these warnings and knowledge of the bank’s actions, Aquino continued to facilitate Sze’s illicit operations.
In one specific instance in February 2021, Aquino facilitated three money laundering transactions for Sze, totaling nearly $2 million in cash. These funds were deposited into an account belonging to a third party, and again, Sze was not identified as the conductor on the relevant reports. In return for his complicity, Sze provided Aquino with retail gift cards valued at approximately $11,000, a tangible reward for his role in the criminal enterprise.
Broader Implications for TD Bank and the Financial Industry
Aquino’s guilty plea and the ongoing investigations into TD Bank’s AML deficiencies highlight a critical vulnerability in the global financial system. The ability of criminal organizations to exploit weaknesses in even large, ostensibly reputable financial institutions poses a significant threat to national security and economic stability. The sheer volume of money laundered—hundreds of millions of dollars in this case—underscores the scale of the challenge faced by regulators and law enforcement.
The DOJ’s actions against TD Bank, including the substantial penalties and asset caps, signal a tougher stance against financial institutions that fail to uphold their AML obligations. The bank’s commitment to rebuilding its AML program, as stated by a TD Bank spokesperson, will be under intense scrutiny. "AML remediation continues to be the bank’s top priority, and TD actively cooperated with law enforcement to support their investigation," the spokesperson said. "TD has made strong progress in rebuilding its AML program, including through deep investments in talent, training, process improvements, and technology."
The success of these remediation efforts will be crucial in restoring confidence in TD Bank and serving as a deterrent to other financial institutions. The investments in talent, training, process improvements, and technology are essential components of a robust AML framework. However, the effectiveness of these measures will ultimately be judged by their ability to prevent future illicit activities.
A Wider Network of Perpetrators
Aquino’s case is not an isolated incident within TD Bank. The DOJ has also brought charges against other individuals connected to money laundering and fraud schemes involving the bank and other financial institutions.
Eddie Low’s Involvement:
Separately, an individual identified as Low, also known by aliases "Mang Wah Low" and "Eddie Low," processed illicit transactions and facilitated approximately $484,572 in fraud at TD Bank. Low received bribes totaling about $26,700 for his cooperation.
Furthermore, between May and August 2022, while employed at a different bank, Low accepted a bribe to open a shell company account. This account was subsequently used by his co-conspirators to facilitate $47,195 in fraudulent activities. In February, Low pleaded guilty to conspiring to commit wire fraud affecting a financial institution and making false bank entries or reports as a bank employee.
Cheungkin Lam’s Guilty Plea:
In May, another former TD Bank employee, Cheungkin Lam, also known as Kelvin Lam, pleaded guilty to defrauding the lender’s customers and bribing an employee at another bank to falsify bank records. Lam worked at a TD Bank branch in Fresh Meadows, New York, and his actions further illustrate the multi-faceted nature of the illicit activities that have plagued the institution.
The Fight Against Financial Crime
These cases collectively paint a grim picture of how individuals within financial institutions can be compromised, enabling vast sums of illicit money to flow through the global financial system. The ties to drug trafficking, particularly fentanyl, underscore the real-world consequences of these financial crimes, which fuel further criminal enterprises and contribute to societal harm.
The DOJ’s persistent efforts to investigate and prosecute these cases demonstrate a commitment to holding both individuals and institutions accountable for their roles in financial crimes. The ongoing scrutiny of TD Bank and similar institutions serves as a critical reminder of the constant need for vigilance and robust compliance programs in the financial sector. As financial technology evolves and criminal networks become more sophisticated, the battle against money laundering and financial fraud requires continuous adaptation and unwavering dedication from all stakeholders. The guilty pleas of individuals like Aquino and Low, while representing individual accountability, are also critical steps in dismantling larger criminal operations and reinforcing the integrity of the financial system. The long-term impact of these investigations will be measured not only in penalties and convictions but in the strengthened defenses against future illicit activities.
