Bank Employees Are Going to Federal Prison for Money Laundering: What the TD Bank Insider Sentencings Mean if Agents Contact You

Federal money laundering defendants are supposed to be cartel financiers and crypto kingpins. The Justice Department's July 15 announcement told a different story. Two former TD Bank employees, an assistant store manager and a retail banker, were sentenced to federal prison for helping other people's money move through the bank. Neither ran a scheme. They processed transactions, accepted bribes and gift cards, and left names off federal reports. One got 46 months. The other got 24. If you work inside a financial institution, or your accounts have surfaced in a federal money laundering investigation, this case shows how the government now builds these prosecutions.

Two TD Bank insiders did not run a laundering network. They processed the transactions that let one operate, and that was enough to convict them.

Key Takeaways

• DOJ sentenced two former TD Bank insiders to 46 and 24 months in prison for facilitating a $474 million laundering network and an account-takeover fraud scheme.
• The charges rested on money laundering conspiracy under 18 U.S.C. § 1956, wire fraud affecting a financial institution under 18 U.S.C. § 1343, and false bank entries under 18 U.S.C. § 1005.
• Currency transaction report failures under 31 U.S.C. § 5313 converted routine teller-window activity into the government's core evidence of concealment.
• The Criminal Division's Bank Integrity Unit is charging officers, managers, and line employees, and South Florida remains one of the busiest money laundering enforcement districts in the country.
• Pre-indictment defense work, before agents finish their interviews, is where bank-insider laundering cases are won or lost.

What Actually Happened at TD Bank

According to the Justice Department's announcement, Wilfredo Aquino, a former TD Bank assistant store manager, used his position to help a money laundering network move money through TD Bank accounts between 2019 and February 2021. The network's leader, Da Ying Sze, known as David, and his co-conspirators pushed roughly $474 million in cash through TD Bank accounts in New York, New Jersey, and elsewhere. David pleaded guilty in 2022 to coordinating a $653 million laundering conspiracy, operating an unlicensed money transmitting business, and bribing bank employees.

Aquino's role was procedural, and that is exactly the point. He processed roughly 1,680 official bank checks for the network, totaling more than $92 million. Nearly every check was funded with a cash deposit over $10,000, which triggered the bank's duty to file a currency transaction report under 31 U.S.C. § 5313. Aquino repeatedly left David off the reports as the true conductor. A colleague warned him the activity looked like money laundering. He kept processing, in exchange for a little over $11,000 in retail gift cards. In January 2026 he pleaded guilty to conspiring to launder monetary instruments, and on July 15 he was sentenced to 46 months.

The second defendant, Edward Low, a former TD Bank retail employee, took at least $26,700 in bribes to pass confidential customer information to outside co-conspirators, who used it to take over accounts and steal $484,572. He later falsified records at a second institution to open a shell company account used for more fraud. He pleaded guilty to conspiring to commit wire fraud affecting a financial institution and to making false bank entries, and was sentenced to 24 months.

Aquino processed roughly 1,680 official bank checks for the network, totaling more than $92 million. He kept about $11,000 in gift cards. That gap between what he pocketed and what he moved is the whole case.

The Government Is Prosecuting Employees, Not Just Banks

These sentencings came out of the Criminal Division's Bank Integrity Unit, working with IRS Criminal Investigation and the FDIC Office of Inspector General. The unit's stated mission includes prosecuting financial institutions and their officers, managers, and employees. After TD Bank's own guilty plea and $1.8 billion Bank Secrecy Act resolution in 2024, prosecutors moved down the org chart to the individuals who touched the transactions.

Look at what the government actually used to convict. Currency transaction reports with the conductor field left blank or filled with the wrong name. Activity that continued after compliance closed related accounts. An internal warning from a coworker. Gift cards and bribes traceable to the customer being serviced. None of this requires a wiretap or a cooperator at the top of the network. It is all sitting in the bank's own records, and IRS-CI and FDIC-OIG know how to read them. Any teller, banker, or branch manager whose name recurs across flagged transactions should assume the government can reconstruct their entire history at the window.

The risk is not limited to New York and New Jersey. South Florida has been a priority money laundering district for decades because of its international banking corridor, and the same Bank Integrity Unit playbook lands in Miami and West Palm Beach dockets regularly. A South Florida federal criminal defense practice sees these fact patterns constantly, from bank employees and from account holders whose deposits get swept into a laundering review.

None of the government's proof required a wiretap or a cooperator at the top of the network. It was sitting in the bank's own currency transaction reports, and IRS-CI and FDIC-OIG know how to read them.

The Statutes and the Real Exposure

Money laundering conspiracy under 18 U.S.C. § 1956 carries up to 20 years per count. Its companion, 18 U.S.C. § 1957, covers transactions over $10,000 in criminally derived funds and carries 10 years. Wire fraud affecting a financial institution under 18 U.S.C. § 1343 carries up to 30 years, as does making false bank entries under 18 U.S.C. § 1005. Bank employees who accept anything of value in connection with bank business face separate exposure under 18 U.S.C. § 215, and the network's leader in the TD Bank case was also charged with running an unlicensed money transmitting business under 18 U.S.C. § 1960. Structuring deposits to evade reporting is its own felony under 31 U.S.C. § 5324.

On knowledge, the government does not need a confession. Willful blindness is enough, and prosecutors build it from circumstances: the closed accounts, the coworker's warning, the repeated omission of the same customer's name from federal reports. One documented warning inside the bank can become the centerpiece of the knowledge case.

"One documented warning inside the bank can become the centerpiece of the government's knowledge case. That is why the closed accounts and the coworker's warning mattered more than any wiretap."— Aaron M. Cohen, Principal Attorney

The Mistakes That Decide These Cases Early

The employees who end up with the worst outcomes almost always make the same early moves. They sit for a bank internal investigation interview without their own lawyer, not realizing the bank's findings will reach regulators and prosecutors. They talk to federal agents at their front door because they assume they are just a witness. They delete texts after learning about the investigation, converting a defensible knowledge case into an obstruction problem. They answer a federal grand jury subpoena by producing everything without strategy or privilege review. And they wait for an indictment before hiring counsel, after the charging decision has hardened.

What a Strategic Defense Looks Like

Early intervention changes outcomes in laundering cases because the charging decision turns almost entirely on knowledge and intent. A pre-indictment defense lawyer's first job is to establish where you sit: witness, subject, or target. That answer dictates whether to engage prosecutors, whether a proffer makes sense, and whether to show that the transactions looked routine from your seat before the government locks in its theory.

For bank employees, the defense often lives in the details of training, alert volume, and supervisory practice. Did compliance actually escalate? Was the employee following branch practice that management tolerated? Those facts can move a case from a § 1956 conspiracy to a regulatory referral, or from an indictment to a declination. Where charges do come, the fight shifts to attributed funds, role in the offense, and the sentencing factors under 18 U.S.C. § 3553(a). Both TD Bank insiders received sentences well below the statutory maximums. That reflects the work a white collar defense attorney does between plea and sentencing.

Why Timing Matters Right Now

The Bank Integrity Unit announced these two sentencings together, on purpose. It is a message that facilitation gets prosecuted, and it signals more insider cases in the pipeline from the TD Bank record. These investigations run on documents that already exist, so the window to influence a charging decision is short. If IRS-CI or FDIC-OIG agents have reached out, if a federal grand jury subpoena has arrived, or if your name appears on reports tied to a flagged customer, get counsel involved before your first interview, not after it.

Common Questions

If federal agents have approached you, your employer has flagged your transactions, or a subpoena has arrived, the decisions you make in the next few weeks will shape everything that follows.

Aaron M. Cohen is a federal criminal defense attorney based in Boca Raton with more than 30 years of experience in federal investigation defense and financial crime matters, in Florida and nationwide.

If you or your loved ones have been arrested, or you believe you are the subject of a federal money laundering investigation, call Aaron M. Cohen, 24 hours a day to get help.

This article is for informational purposes only and does not constitute legal advice. Reading this article does not create an attorney-client relationship. Every case is different, and outcomes depend on specific facts and circumstances. If you are facing a federal investigation or criminal charges, consult a qualified attorney about your situation.