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Organization Changes Spark Confidence in TD Bank’s AML Controls

td bank stuart davis anti-money laundering controls

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TD Bank has taken decisive steps to overhaul its anti-money laundering (AML) framework, leveraging expert leadership and strategic restructuring to fortify its defenses against financial crime risk. The recent departure of Stuart Davis, a renowned financial crimes adviser, marks the conclusion of a pivotal chapter in the bank’s journey toward compliance excellence. Over the past ten months, TD has enacted significant measures to strengthen its AML controls, streamline decision-making, and embed cutting-edge technologies.

Stuart Davis joined TD Bank last summer as a special adviser to Chief Risk Officer Ajai Bambawale. With more than three decades of AML and regulatory risk management experience across North America, Davis was tasked with helping TD navigate enforcement actions from U.S. regulators, including the Department of Justice and the Federal Reserve.

Davis’s appointment coincided with TD’s historic guilty plea to conspiracy to commit money laundering, becoming the first U.S. bank to admit such charges for moving illicit funds on behalf of drug cartels. The penalties imposed—over US$3 billion in fines and a cap on asset growth—underscored the urgent need for robust financial crime risk controls. Davis’s role, originally conceived as a short-term contract, provided expert guidance on remediating compliance gaps, redesigning monitoring frameworks, and embedding a culture of accountability across business lines.

Drawing on his tenure as Global Chief AML Officer at the Bank of Montreal and Executive Vice-President of Financial Crimes Risk Management at Scotiabank, Davis delivered actionable recommendations that enhanced TD’s risk assessment methodologies and transaction monitoring rules. His focus on pragmatic, technology-driven solutions laid the groundwork for sustainable improvements in the bank’s anti-money laundering controls.

Strategic Team Realignment to Drive AML Efficiency

Under new CAMLO Jacqueline Sanjuas, appointed in January, TD’s financial crime risk management team has undergone a targeted restructuring. Three senior vice-presidents—Sohana Inderlall, Caitlin Riddolls, and Rick Hamilton—departed as part of a broader effort to simplify the operating model in Canada.

Sanjuas emphasized clarity in decision-making, consistent mandates, and streamlined governance processes. By consolidating oversight functions and standardizing policies across regional platforms, the bank aims to accelerate case investigation times and improve the precision of suspicious activity reporting.

Sanjuas’s leadership has also prioritized talent acquisition, with dozens of new hires in AML and compliance roles. The integration of dedicated technology experts reflects TD’s commitment to harnessing machine learning and advanced analytics for real-time transaction monitoring and risk scoring.

Investing in Technology to Combat Financial Crime Risk

TD’s remediation plan, expected to cost approximately US$500 million in pre-tax expenses during the fiscal year, includes significant investments in innovative compliance technologies. The bank is deploying:

Advanced Analytics Platforms: Machine learning models that detect anomalous patterns and adapt to evolving typologies of illicit finance.
Enhanced KYC/KYB Tools: Digital identity verification solutions that streamline customer onboarding while maintaining rigorous due diligence standards.
Automated Screening Systems: Integrations with global sanctions databases to ensure real-time compliance with OFAC, UN, and EU lists.

These initiatives align with regulatory expectations under the Bank Secrecy Act and anti-money laundering provisions of the USA PATRIOT Act. By automating high-volume, repetitive tasks, TD frees compliance professionals to focus on complex investigations and strategic risk management.

Embedding a Culture of Continuous Improvement

Beyond technology, TD has reinforced its commitment to a risk-aware culture through enhanced training programs and accountability frameworks. Regular scenario-based exercises, led by senior executives, cultivate cross-functional collaboration between compliance, operations, and business units.

The bank’s revamped governance structure establishes clear escalation pathways for high-risk alerts and well-defined roles for first-, second-, and third-line defense functions. This organizational clarity mitigates the risk of oversight gaps and ensures that compliance decisions are made by personnel with the requisite expertise.

Looking Ahead: Completing Remediation by 2025

TD has set an ambitious timeline to complete the majority of its remediation actions by December 31, 2025. This roadmap includes rolling out unified monitoring platforms in Canada and the U.S., enhancing data quality controls, and expanding the scope of transaction reviews.

The departure of Stuart Davis, while signaling the end of his contract, coincides with a sustainable, in-house capability that leverages both experienced leadership and modern technologies. As TD Bank continues to refine its anti-money laundering controls, it positions itself not only to meet regulatory requirements but to set industry benchmarks in financial crime prevention.

Conclusion

TD Bank’s strategic overhaul—anchored in expert advisory, team realignment, technology investment, and cultural reinforcement—demonstrates a comprehensive approach to managing financial crime risk. With a clear remediation timeline and renewed internal capabilities, the bank is poised to restore stakeholder confidence and safeguard its global operations against illicit finance threats.