A recent guilty plea by a former TD Bank teller who helped move millions in suspicious funds through the U.S. banking system is an illustration of how easily things can go wrong when frontline staff face few internal anti-money laundering (AML) controls, according to a new report by the American Banker. 

Leonardo Ayala, 25, admitted to conspiracy to launder monetary instruments and to receiving bribes as a bank employee, according to a U.S. Justice Department announcement published Friday. Along with his co-conspirators, Ayala helped launder approximately $5.5 million on in exchange for over $6,000 in bribes paid in cash and a peer-to-peer payment service. 

Prosecutors said the scheme relied heavily on remote-servicing capabilities and other authorities available to tellers and retail bankers, according to the report. 

A co-conspirator, identified in court documents as former TD employee Oscar Marcelo Nunez-Flores, allegedly opened shell-company accounts at a bank branch in Scotch Plains, New Jersey, listing “straw” owners in place of the criminals behind the scheme, the Banker reported.  

In one case, Nunez-Flores used the identifying documents of a 77-year-old Colombian woman to mask the real beneficiary, according to the Banker. While the account had only one listed owner, the criminal group sought multiple debit cards to withdraw cash more quickly in Colombia and to get around daily ATM withdrawal limits, the news outlet said. 

Ayala accepted bribes to order debit cards tied to the shell-company accounts using identities of people who were not authorized signers, described in the filings as “fictitious employees” of the shell companies, according to the report. Accomplices emailed lists of names and dates of birth directly to Ayala’s TD email address, which he used to place debit-card orders. 

Ayala also accessed a shell-company account while working the drive-through window at a TD branch in Doral, Florida, and issued 25 debit cards for a business account that had been opened in New Jersey. He selected “Mail to Customer” to send the cards to an address in Plainfield, New Jersey, rather than handing them to a customer at the branch, the news outlet reported.  

Once activated, the cards were ultimately used in Colombia, where the cash-withdrawal phase of the laundering operation took place, according to the Banker. 

Ayala, for his part, maintained a clear menu of services: $700 to open a business account, $150 for a personal account, and $50 for each debit card order. Prosecutors say Ayala used acquaintances as intermediaries to conceal bribe payments. 

The case highlights “major shortcomings in TD’s internal monitoring and guardrails against insider wrongdoing,” including its failure to stop Ayala from issuing dozens of debit cards for a single business account. 

Read more at the American Banker

Read more at the Justice Department