Banker Prosecutions Raise Concerns of Insider Threat in US, Britain

Koos Couvée
London Bureau Chief

In March, federal prosecutors in Newark, New Jersey, charged Gerardo Aquino, a 38-year-old banker in Hollywood, Florida, with obstructing justice by lying about using false names and addresses to open accounts for unidentified parties outside the U.S. in return for $200 bribes.

Aquino, who identifies himself on LinkedIn as a finance associate at TD Bank’s branch in Hollywood, opened 28 accounts in May and June of last year for one of the co-conspirators, according to the complaint against him. The accounts were then used to withdraw millions of dollars from ATMs in Colombia with debit cards Aquino allegedly provided.

After the alleged co-conspirator texted him in August of last year that the bank had frozen some of the accounts, prosecutors claim Aquino called the lender’s debit-card hotline to vouch for the transactions that had raised suspicion, and succeeded in unlocking two of them.

The case against the 38-year-old, who joined the bank more than 10 years before the alleged conduct began, marks the latest in which criminals appear to have paid frontline staff or third-party vendors to undermine the anti-financial crime defenses of their employers, and comes after global financial institutions surveyed by ACAMS identified the “insider threat” as a top concern.

“As institutions have built up their controls, there are maybe [fewer] holes from the outside,” Craig Timm, U.S. senior director of AML at ACAMS, said during a webinar on the insider threat last month. “So [money launderers] need to work with people inside.”

Aquino allegedly accepted at least $5,600 into his own account at the bank in exchange for assisting his co-conspirators, who routed many, if not all, of those bribes through Zelle, a rapid-payments platform owned by a consortium of seven of the largest banks in the U.S.

Since disclosing charges against Aquino, prosecutors have publicly accused at least three former bankers in Indiana and California with using their positions to assist criminals.

One of the accused allegedly cashed stolen checks for fraudsters, while the other two allegedly converted drug cash from lower- to higher-denominations.

Concerns over the typology have grown outside the U.S. as well.

In December, the U.K. Crown Prosecution Service charged a former director of First Bank of Nigeria’s affiliate in London with taking bribes from 2011 to 2014 in exchange for overlooking transactions involving a Nigerian oil executive suspected of corruption.

Spokespersons for TD Bank did not confirm Aquino’s previous employment by press time.

TD Bank targeted?

TD Bank, which has set $450 million aside to cover an anticipated anti-money laundering penalty in the U.S., announced Friday that a comprehensive overhaul of its U.S. AML program is “well underway.”

In October 2023, prosecutors charged Oscar Marcelo Nunez-Flores, “sales leader” at TD Bank’s branch in Scotch Plains, New Jersey, with conspiring to launder $4.2 million of drug-trafficking proceeds in exchange for $20,000 of bribes.

The suspected traffickers and their associates deposited millions of dollars into accounts that Nunez allegedly opened for shell companies at TD Bank, then used debit cards to withdraw them in Colombia. Prosecutors further allege that the 32-year-old former sales leader ensured that any transactions that may have raised an alarm escaped his employer’s notice.

In a third case involving an allegedly compromised employee at TD Bank, Diape Seck, a former customer-service representative in Silver Spring, Maryland, was convicted of fraud and bribery after using false records to open 412 accounts that at least eight co-conspirators used to cash nearly $2 million of stolen checks up to January 2020.

Federal investigators separately warned lawmakers last month that members of “Chinese money laundering organizations” have sought to bribe financial services professionals for details on the account- and transaction-monitoring practices of their employers, and have sometimes managed to get jobs at the banks they want to exploit.

Molly Moeser, acting chief of the Justice Department’s Bank Integrity Unit told attendees of an ACAMS-hosted conference in Florida in April that her agency has prosecuted five employees of banks and credit unions over the past year for selling inside information to money launderers.

“You really have to be attuned to what is happening at the retail level—this is where money launderers will exploit your system,” Moeser said.


Tracey Carpenter, insider-threat manager at Cifas, a fraud-prevention agency in Britain, told attendees of an ACAMS-hosted conference in Amsterdam last month that dishonesty among financial services employees is driven not only by personal greed, but also by gambling addiction and the rising cost of living.

Remote working arrangements have also driven corruption, as personnel are less likely to be overheard discussing their involvement in illegal schemes or seen using their personal devices to communicate with parties outside the institution.

On April 30, federal prosecutors in Philadelphia charged Kalien Frazier, a 29-year-old resident of Oakland, California, with fraud and identity theft after he allegedly sold the account credentials and personal details of hundreds of customers to criminals while working as a remote customer-service employee of an unidentified bank from March 2022 to August 2023.

Frazier allegedly obtained the debit-card numbers, “card verification values,” also known as CVV, and personal details from clients of the bank while on recorded customer-service calls with them, then offered to sell the information to fraudsters in online “group chats.” A lawsuit filed in Oakland identifies Frazier’s employer at that time as U.S. Bank.

Banks tend to assign personnel involved in complex financial-crimes investigations to look into employees suspected of corruption.

Anand Sithian, a partner at Crowell & Moring in New York, said during last month’s webinar that because criminals often connect with employees socially—through mutual acquaintances, for example—banks must train their staff to report any offer, however oblique, to pay them for information on their AML controls.

Financial institutions should also file “zero-amount” suspicious activity reports on potential insider threats regardless of whether any accounts, information or systems were compromised; set up a hotline for employees to report possible schemes without fear of retaliation; and ensure that internal investigators will protect their anonymity when reviewing their complaints.

Institutions can also raise their chances of spotting insider-enabled illicit transactions by automatically logging when employees access confidential records and systems, Ed Cook, head of global investigations at JPMorgan Chase, said during the webinar.

“I think you have to have a very robust set of data about what employees are doing that you can layer on top of [transaction monitoring],” Cook said.

Contact Fred Williams at and Koos Couvée at

Topics : Anti-money laundering , Corruption/Bribery
Source: U.S.: Department of Justice , United Kingdom
Document Date: June 5, 2024