Banking and Finance Law Daily Wrap Up, BANK SECRECY ACT—D.N.J.: Former TD Bank employee pleads guilty to facilitating money laundering, (Jan 7, 2026)

By Justin Marcus Smith, J.D.

The DOJ said the former employee “helped criminals launder money from inside TD Bank.”

A former TD Bank N.A. employee, Wilfred Aquino, has pleaded guilty in the federal district court in Newark, New Jersey, to a one-count Information charging him with conspiracy to launder money, the Department of Justice (DOJ) announced. The Information focused on failures to file Currency Transaction Reports (CTRs) while Aquino worked at TD Bank in Midtown Manhattan. Aquino “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 DOJ Criminal Division Assistant Attorney General A. Tysen Duva. The charge of money laundering conspiracy carries a maximum penalty of 20 years imprisonment and a fine of $500,000, or twice the amount involved in the offense, whichever is greater. Aquino awaits sentencing on May 12, 2026. According to the plea agreement, Aquino’s Total Offense Level may be 23, depending on fulfillment of certain conditions. Aquino also agreed to forfeiture and restitution (United States v. Aquino, No. 2:25-cr-00689-ES (D.N.J. Jan. 6, 2026)).

Background. As previously reported, the DOJ and the U.S. Attorney's Office for the District of New Jersey, in conjunction with the Federal Reserve Board, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN), and the Office of the Comptroller of the Currency, took criminal and regulatory actions against TD Bank Group, including TD Bank, N.A., TD Bank USA, N.A., and related holding companies (collectively, TD Bank). The DOJ and regulators alleged TD Bank violated the Bank Secrecy Act (BSA) and anti-money laundering (AML) laws. The DOJ obtained consent orders that required TD Bank to pay more than $3 billion in penalties and fines and pleading guilty to criminal charges. The bank admitted that it “willfully failed to implement and maintain” an appropriate AML compliance program that allowed trillions of dollars in transactions to go unmonitored annually. The bank also said it took full responsibility (see Banking and Finance Law Daily, Oct. 11, 2024).

Aquino Information. According to the DOJ announcement and the Aquino criminal Information, Aquino, as a TD Bank assistant store manager, helped the so-called “David’s Network” to move about $474 million through TD Bank accounts by depositing cash at TD Bank stores, including stores in New York and New Jersey. Aquino may have been “Insider-1 . . . a former Financial Service Representative at a TDBNA store in New Jersey” as spelled out in the separate 2024 two-count Information against TD Bank.

In February 2022, Da Ying Sze, also known as David, pleaded guilty to coordinating a total of $653 in conspired money laundering, operating an unlicensed money transmitting business, and bribing bank employees. According to the DOJ, most of the money went through the TD Bank Midtown Manhattan retail platform, and no one processed more of the David’s Network transactions at that store than Aquino. Aquino allegedly processed 1,680 official bank checks totaling more than $92 million, each with a corresponding cash deposit that exceeding $10,000, which should have triggered a CTR. Aquino allegedly knew TD Bank closed other accounts linked to David for suspicious activity, but he failed to report David as the conductor of suspicious transactions, which the DOJ said were money laundering. The Aquino criminal Information alleged TD Bank provided pertinent CTR training to Aquino in 2018, 2019, and 2020.

The Information incorporated purported video still-frames of Aquino processing a large cash transaction for David. The still-frames appeared to show more than four stacks of cash, each about a half-foot in height, piled on the counter at Aquino’s teller position. The still-frames also appeared to show that Aquino accepted from David a “digital photo of an absent nominee accountholder’s identification” and that David, a few minutes later, gave Aquino a stack of retail gift cards as alleged personal compensation for the transaction.

Plea agreement. The Sept. 4, 2025, plea agreement offer the DOJ said Aquino accepted described the potential sentencing of up to 20 years imprisonment, the potential fines, and potential supervised release of up to three years, at the sole discretion of the judge. The government and Aquino nevertheless agreed to a 16-level increase in the offense level because the offense allegedly involved about $2 million; a 2-level increase because Aquino allegedly violated 18 U.S.C. 1956; and a 2-level increase because Aquino allegedly abused a position of public or private trust that significantly facilitated the commission and concealment of the offense.

However, the government acknowledged Aquino “clearly demonstrated” personal responsibility for the offense charged, so it agreed to a downward adjustment of 2-levels. The government said it would also move at sentencing for a further 1-point reduction in Aquino’s offense level if Aquino enters the plea agreement, if the government determines that Aquino has demonstrated continuing acceptance of responsibility through the date of sentencing, and if the offense level is 16 or greater. Overall, the agreed Total Offense Level is 23, or perhaps 25, depending on certain conditions.

Aquino apparently agreed to pay restitution, forfeiture, and to give reasonable notice and explanation of his conviction to any victims. He apparently further agreed to provide a complete and accurate Financial Disclosure Statement on government request; accepted potential immigration consequences if he is not a citizen; and agreed to consent to any regulatory action taken by any federal financial regulatory agency to permanently bar him from participating in the affairs of any insured depository institution or other entity as described in Section 8(e) of the Federal Deposit Insurance Act.

The plea agreement applies only to the United States Attorney’s Office for the District of New Jersey and the Money Laundering and Asset Recovery Section of the DOJ. It said it does not bind other federal, state, or local authorities.

Companies: TD Bank, N.A.; TD Bank Group; TD Bank USA, N.A.

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