Daily Compliance Brief — DOJ Guilty Plea Exposes Bank Insider Money Laundering Risk

October 6, 2026

Signal

The U.S. Department of Justice (DOJ) announced on October 6, 2026 that former TD Bank employee Gerardo Aquino pleaded guilty to accepting bribes and laundering more than $4.8 million to Colombia. According to a DOJ press release, Aquino exploited his position inside the bank to facilitate the movement of illicit funds.

Court filings cited by the DOJ state that between April 2022 and November 2023, Aquino opened fraudulent accounts, issued hundreds of debit cards to co-conspirators, and unblocked cards that TD Bank had restricted for potential fraud. He also opened 86 individual customer accounts using the same commercial address, which were used to launder more than $3 million.

Why it matters

The case highlights the financial crime exposure created when employees can override or circumvent customer and transaction controls. Firms should assess whether privileged access, account-opening processes, fraud alerts, and restriction overrides are subject to appropriate segregation and independent review.

Control environments may require stronger monitoring of employee activity, unusual account-opening patterns, repeated common addresses, and overrides of existing fraud controls, particularly where employee actions can materially alter customer risk or transaction restrictions.