Financial Crime Developments, Resources and Stories: January 2026 Edition

January 8, 2026
3 min read

Welcome to the January 2026 summary of news you can use as your bank or other financial institution attempts to stay up to date on the world of BSA/AML compliance. Our monthly series of curated news about FinCrime regulatory developments, resources and stories.

In this edition, three main stories emerge that underscore the need for better adherence to CTR rules, customer vetting procedures, and institutional self-checks:

A TD Bank insider pleads guilty to facilitating money laundering
The U.K. Financial Conduct Authority hit Nationwide with a £44 million penalty
FinCEN has assessed a $3.5 million penalty against Paxful for facilitating suspicious activity involving illicit actors

TD Bank insider pleads guilty to facilitating money laundering

On January 6, 2026, the US Department of Justice announced that a former New York-based employee of TD Bank N.A, Wilfredo Aquino, pleaded guilty to facilitating a money laundering network’s movement of hundreds of millions of dollars through TD Bank accounts.

“The defendant 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 Assistant Attorney General A. Tysen Duva of the Justice Department’s Criminal Division. “During the illicit scheme, the defendant evaded reporting requirements to hide the identity of the leader of the money laundering network.”

The leader of the network, Da Ying Sze (aka David) and his co-conspirators moved nearly $500 million through TD Bank accounts by depositing cash at TD Bank stores in New York, New Jersey, and elsewhere.

Aquino processed approximately 1,680 official bank checks for the “David” Network, totaling more than $92 million. Nearly all of the bank checks were funded with a corresponding cash deposit exceeding $10,000, which triggered TD Bank’s legal requirement to file a currency transaction report (CTR). Although Aquino knew that David was conducting these cash deposits, Aquino never identified David as the “conductor” on the CTR.

The FCA hits Nationwide with a £44 million penalty

On December 12, 2025, The U.K. Financial Conduct Authority disclosed a £44 million penalty Friday against Nationwide for failing to properly vet retail customers, including an individual who received tens of millions of pounds in fraudulent proceeds.

The FCA said in a 42-page enforcement notice that the Swindon-based building society, a type of mutual bank, failed to conduct adequate due diligence and risk assessments on all of its personal checking-account clients and did not properly monitor their transactions from October 2016 through July 2021.

In one particularly egregious case, Nationwide failed to flag a customer who used several personal accounts to receive more than £27 million derived from fraud schemes, even though most of the £27 million was deposited in a single week, according to the FCA.

FinCEN assesses a $3.5 million penalty against Paxful for facilitating suspicious activity

On December 9, 2025, (FinCEN) announced that it assessed a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (collectively, Paxful) for willful violations of the Bank Secrecy Act (BSA).

Paxful is a convertible virtual currency (CVC), peer-to-peer (P2P) trading platform that facilitated more than $500 million in suspicious activity involving a number of different illicit actors. The company enabled transactions with countries including Iran, North Korea, and Venezuela, along with Backpage.com, a website seized by the Department of Justice in 2018 for facilitating prostitution and sex trafficking.

Paxful admitted that it willfully violated the BSA, including failing to: (i) register with FinCEN as a money services business (MSB); (ii) develop, implement, and maintain an effective AML program; and (iii) file suspicious activity reports (SARs).

According to FinCEN Director Andrea Gacki, “FinCEN is committed to mitigating risks to the U.S. financial system while fostering responsible innovation in the virtual asset ecosystem.”