Honestly, it has been a brutal couple of years for TD Bank. If you haven't been following the play-by-play, the bank has basically been living in a regulatory nightmare that feels less like a corporate hiccup and more like a full-blown crisis. When news broke that another high-level TD Bank AML officer steps down, specifically Chief Global Anti-Money Laundering Officer Herbert Mazariegos in early 2025, it didn't just cause a ripple in the financial world—it sent a clear signal that the house-cleaning is far from over.
Mazariegos had only been in the role for a relatively short stint, joining from BMO in late 2023. His sudden exit, described by the bank as "stepping down immediately" in January 2025, came right as the bank was scrambling to fix what the U.S. Department of Justice called "pervasive and systemic" failures.
You've gotta wonder what it's like in those boardrooms. One day you're the 10th largest bank in the U.S., and the next, you're the first national bank in history to plead guilty to conspiracy to commit money laundering.
Why the TD Bank AML Officer Steps Down Amid $3 Billion Fines
The departure of Mazariegos is just one piece of a much larger, very expensive puzzle. To understand why a TD Bank AML officer steps down in this climate, you have to look at the staggering numbers. In October 2024, TD Bank agreed to pay roughly $3.09 billion in penalties to U.S. regulators. That's not a typo. $3 billion.
What's even wilder is how long this was going on. For about a decade, TD allegedly operated with a "flat-cost" paradigm. Basically, they kept their compliance budget the same year after year while the bank grew like crazy. It’s like trying to guard a growing mansion with the same two security cameras you bought for a studio apartment in 2014.
The results were catastrophic:
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- Over $18 trillion in transactions went unmonitored between 2018 and 2024.
- The bank failed to monitor about 92% of its total transaction volume.
- Criminal networks used TD to move more than $670 million, including cash from fentanyl trafficking.
The Replacement Strategy: Enter Jacqueline Sanjuas
When Mazariegos left, TD didn't waste time. They tapped Jacqueline Sanjuas to take over as the Global Head of Financial Crime Risk Management. Sanjuas is a Citi veteran who actually joined TD in early 2024 to run the U.S. side of things.
The bank is betting big on her. They’ve already hired over 700 new AML specialists and 40 new leaders. It's a total overhaul. But here's the kicker: she’s not just filling a seat. By May 2025, Sanjuas was already cleaning house further, with three more vice presidents—Sohana Inderlall, Caitlin Riddolls, and Rick Hamilton—also departing the financial crime team. It seems the bank is moving away from the old guard entirely to try and satisfy the U.S. regulators.
A CEO Under Fire and a Capped Future
The "TD Bank AML officer steps down" headline is actually part of a much bigger leadership purge. Bharat Masrani, the long-time CEO, saw his 2024 pay slashed by nearly 90%. He went from making over $13 million to about $1.5 million. He eventually stepped down early, with Raymond Chun taking the reins in February 2025.
But the real "death blow" for TD’s growth isn't just the fine; it's the asset cap. The Office of the Comptroller of the Currency (OCC) slapped a $434 billion cap on their U.S. retail assets.
If you're a shareholder, this is the scary part. It means TD literally cannot grow in the U.S. right now. They can't open new branches or expand their balance sheet until the government is convinced they’ve fixed their AML mess. Wells Fargo has been under a similar cap for years, and it’s been a massive drag on their stock.
What This Means for You (The Actionable Part)
If you bank with TD or invest in them, this isn't just "inside baseball" corporate news. It affects how they operate.
- Expect Slower Onboarding: If you're opening a business account or moving large sums of money, expect way more friction. They are over-correcting. "Know Your Customer" (KYC) checks are going to be much more intrusive than they used to be.
- Watch the Asset Cap: This is the metric to track. Until that $434 billion cap is lifted, TD is a "zombie bank" in the U.S. retail space. Don't expect aggressive new mortgage products or high-yield savings expansions while they are in the penalty box.
- Internal Culture Shifts: If you work in fintech or compliance, TD is currently the largest hiring hub for AML talent. They are throwing money at the problem to try and buy back their reputation.
- Follow the Court Cases: As recently as January 2026, former employees like Wilfredo Aquino have been pleading guilty to helping money launderers from the inside. This suggests the "remediation" is going to take years, not months.
The lesson here is simple: you can't outrun a bad compliance culture. When a TD Bank AML officer steps down, it's usually because the pressure from the DOJ and the OCC has become unsustainable. The bank is now in a race to prove it can be "convenient" for customers without being "convenient" for criminals. It’s a tough balance to strike, and they’re starting from a deep, deep hole.
To stay ahead of how this affects your portfolio or your personal accounts, keep an eye on the quarterly reports regarding "remediation costs." Those are the real numbers that will tell you if the new leadership, headed by Sanjuas and Chun, is actually making headway or just spinning their wheels in a regulatory mud pit.