The individual prosecutions now flowing out of the TD Bank money laundering scandal are a reminder that institutional control failures are ultimately executed, or ignored, one employee at a time. This week, U.S. District Judge Esther Salas sentenced former TD Bank assistant manager Wilfredo Aquino to 46 months in prison and three years of probation for his role in a money laundering conspiracy that moved...

The SEC’s latest enforcement action against Merrill Lynch is a reminder that a transaction monitoring system is only as good as the calibration behind it. On July 1, 2026, Merrill agreed to pay a $7.5 million civil penalty, accept a censure, and consent to a cease-and-desist order to settle SEC charges that it failed to file numerous Suspicious Activity Reports (SARs) between April 2020 and...

On June 30, 2026, EagleBank agreed to pay more than $9.7 million to resolve a Bank Secrecy Act investigation into more than a decade of willful AML/CFT program failures tied to a check kiting scheme run by a father-son pair with a personal relationship to the bank’s own former chairman and CEO. The Justice Department’s non-prosecution agreement with EagleBank and its parent, Eagle Bancorp Inc.,...

This is Part 3 of a 3-part series on internal investigations in the age of AI. Join Michael for a webinar on September 8, 2026 on this topic — Register HERE. Most of the conversation about AI and internal investigations focuses on AI as a tool — how investigators can use it, and how to manage the risks when they do. But there is a...

This is Part 2 of a 3-part series on internal investigations in the age of AI. Join Michael for a webinar on September 8, 2026 on this topic — Register HERE. AI tools promise to transform internal investigations — faster document review, instant summaries of witness interviews, pattern detection across millions of communications. The promise is real. So are the risks. Companies rushing to deploy...