Following mounting scrutiny in recent years over several AML-related issues and regulatory investigations, TD Bank is in the spotlight once again — but this time, for trying to turn the page. As the bank works to restore trust and regulatory confidence, its new global anti money laundering chief Jacqueline Sanjuas announced the sweeping leadership overhaul of its financial crime risk division. The shakeup comes after a record-breaking $3 billion penalty issued by U.S. regulators for systemic anti-money laundering (AML) failures, including inadequate oversight of transactions linked to human trafficking and fentanyl trafficking.
What happened?
TD Bank was fined a staggering $3 billion by U.S. regulators in October 2024 after failing to detect and prevent illicit activity flowing through its systems. U.S. Attorney General Merrick Garland said TD created an environment “that allowed financial crime to flourish…By making its services convenient for criminals, it became one,” he said in a press conference.”Today, TD Bank became the largest bank in U.S. history to plead guilty to Bank Secrecy Act program failures, and the first bank in history to plead guilty to conspiracy to commit money laundering.”
According to investigative reports, U.S. authorities identified critical weaknesses in the bank’s AML programmes, particularly in its failure to act on internal alerts related to suspicious activity tied to drug trafficking and human exploitation.
As part of the enforcement settlement, TD Bank has also agreed to a four-year independent monitorship to oversee improvements to its compliance systems.
The overhaul: Who’s out and why?
Jacqueline Sanjuas, TD Bank’s new Global Head of Financial Crime Risk Management, assumed leadership of the division earlier this year and wasted no time reshaping the team. In a company-wide memo, she announced the departure of three senior vice presidents:
- Sohana Inderlall, VP of Risk and Business Control Programmes
- Caitlin Riddolls, VP of Risk Oversight, Canadian Banking
- Rick Hamilton, VP of Data and Model Management
According to Sanjuas, the changes aim to “simplify the financial crime risk operating model in Canada,” create clearer lines of accountability, and “better enable decision making and execution” across the bank’s global operations. Two interim leaders, Georgia Stavridis and Stephen Joyce, have been appointed while the search for permanent successors continues.
What are the implications for the financial services sector?
This enforcement action against TD Bank should ring alarm bells across the financial services sector. The bank’s failures did not stem from a lack of policy or infrastructure on paper — they were rooted in deeper issues of execution, accountability, and a culture that prioritised growth over compliance. Here are the key takeaways:
1. Leadership accountability is not optional
When regulators demand results, they expect to see responsibility at the top. The departure of three senior vice presidents signals that executive leadership will be held personally accountable for systemic failures.
2. Simplifying the model doesn’t mean weakening compliance
Sanjuas’ comments about “simplifying” the AML structure speak to a growing trend in compliance: removing bureaucracy to empower teams to act decisively. Clarity of roles, reduced silos, and streamlined communication are vital — especially when fast decisions are needed on high-risk alerts.
3. Technology must be paired with human judgment
TD reportedly failed to act on alerts generated by their own systems. This is a cautionary tale about over-reliance on tech. Automated tools are critical, but they must be matched with training, investigation protocols, and a culture of scrutiny.
4. Regulators are increasing the pressure
From the U.S. to the UK, AML enforcement is escalating. In 2023–24 alone, multiple global financial institutions faced large-scale penalties. With further regulation incoming — including new EU AML laws and updated guidance from the UK’s LSAG — firms must ensure their frameworks are not just legally compliant, but practically effective.
How VinciWorks can help
Financial institutions, law firms and other entities can easily fall out of compliance or get caught up in dirty money without a robust AML framework.
- Omnitrack’s adaptive Client Onboarding Solution platform streamlines risk assessments, client due diligence, and ongoing monitoring, offering unparalleled flexibility and industry-specific guidance.
- Packed with realistic scenarios, real-life case studies and customisation options, Vinciworks’ suite of AML courses will help you stay protected. Our courses include role-specific modules for front-line staff and senior leaders, ensuring your teams are prepared to identify and act on red flags.
TD Bank’s case is a reminder that AML compliance is not just a regulatory obligation — it’s a matter of public trust and corporate survival. While penalties and monitor appointments make headlines, the real impact is reputational, operational, and cultural.
As regulators continue to sharpen their expectations, organisations must move beyond tick-box compliance and invest in meaningful risk management strategies. The cost of getting it wrong has never been higher.
