Former TD Bank Employee Wilfredo Aquino Pleaded Guilty to Facilitating Money Laundering Network

By the Constantine Cannon Whistleblower Team

On January 7, the government announced that New York-based former TD Bank N.A. assistant branch manager, Wilfredo Aquino, 47, pleaded guilty to facilitating a money laundering network to move hundreds of millions of dollars through TD Bank accounts from 2019 through February 2021.[1]

David and His Co-Conspirators’ Scheme

The network’s leader, Da Ying Sze (aka David) and his conspirators (collectively known as David’s Network) moved roughly $474 million through TD Bank accounts by depositing cash at TD Bank branches in New York and New Jersey.[2]

David Pleaded Guilty in 2022

David pleaded guilty in February 2022 to orchestrating a $653 million money laundering conspiracy, operating an unlicensed money-transmitting business, and bribing bank employees to facilitate financial transactions.[3]

How Did Aquino Facilitate the Transactions?

As part of David’s money laundering operation, Aquino processed approximately 1,680 official bank checks for the network, worth more than $92 million. Nearly all of the checks were backed by cash deposits exceeding $10,000, which triggered TD Bank’s obligation to file currency transaction reports.[4]

Aquino was aware that TD Bank previously shut other accounts tied to David for suspicious activity. Still, in February 2021, Aquino helped process three transactions totaling nearly $2 million in cash through a third party’s account and failed to list David as the conductor, in attempts to hide his involvement in the scheme.

Aquino received over $11,000 in retail gift cards in exchange for facilitating the scheme, including the three transactions in February 2021.[5]

Aquino Pleaded Guilty

Aquino pleaded guilty to one-count of conspiracy to launder monetary instruments. His sentencing is scheduled for May 12.

The charge carries a potential sentence of up to 20 years’ imprisonment and a fine of up to $500,000 or twice the value of the funds involved, whichever is greater.

How are AML and Sanctions Laws Enforced?

Banks and other financial institutions must comply with laws and regulations such as the Bank Secrecy Act (BSA) and related regulations designed to detect and prevent money laundering. Financial institutions that fail to maintain effective anti-money laundering (AML) controls face criminal and civil liability. The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) administers the BSA, and OFAC administers and enforces economic and trade sanctions laws.[6]

What Role Can Whistleblowers Play in Reporting Violations of AML Laws?

Whistleblowers with information about AML failures and sanctions violations can play an important role in alerting regulatory agencies about the fraudulent schemes that might otherwise continue undetected.

Constantine Cannon partner Marlene Koury stated: “This enforcement action highlights the risks of failing to maintain effective AML controls. While we do not know whether this case involved a whistleblower, whistleblowers are often best positioned to identify compliance failures, report misconduct, and help protect the integrity of the financial system.”

Whistleblower Rewards

Through the Anti-Money Laundering Act of 2020 (AMLA), enacted as part of the National Defense Authorization Act at the end of 2020, Congress created a new Anti-Money Laundering Whistleblower program.  Under the law, whistleblowers who provide information that leads to monetary sanctions for violations of the BSA can be entitled to an award of up to 30% of the monetary sanctions recovered.

Our Firm Helps AML Whistleblowers

If you have information about potential AML and BSA violations or questions about what it means to be a whistleblower under the various government programs, please contact us. We will put you in touch with an experienced member of our whistleblower team for a free and confidential consultation.

Speak Confidentially With Our Whistleblower Attorneys

Sources:

[1] See https://www.justice.gov/opa/pr/td-bank-insider-pleads-guilty-facilitating-money-laundering

[2] Id.

[3] Id.

[4] Id.

[5] Id.

[6] See https://www.fincen.gov/

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