Stuart Davis, a financial crime expert who aimed to enhance anti-money laundering controls at TD Bank, has left the institution following the termination of his contract. An American with extensive experience in money laundering and regulatory risk management across Canada and the US, Davis joined TD Bank last summer as an advisor to Chief Risk Director Ajaybanbawal. The bank described his role as a short-term arrangement at the time.
Davis was brought on board during a crucial period as the bank faced investigations from US banking regulators and the Department of Justice. Notably, last fall, TD became the first US bank ever to plead guilty to conspiracy to commit money laundering for facilitating the transfer of funds for drug cartels and criminal organizations over a decade. The repercussions included fines exceeding US$3 billion and several non-monetary penalties, like limitations on asset growth.
His departure aligns with changes initiated by TD’s new Chief Anti-Money Laundering Officer, Jacqueline Sanjuas, who is reorganizing the bank’s financial crime risk management team. An internal memo indicated that Sanjuas recently communicated the exit of three executives from the team.
Sohana Inderlall, Vice Chairman of Risk and Business Control Program, Canadian Banking Platforms and Technology representative Caitlin Riddolls, and Rick Hamilton, Vice Chairman of Data and Model Management, are all pursuing new opportunities. The memo stated that former Camlo Herb Mazariegos was appointed to lead TD’s financial crime efforts in January and restructured the team to “simplify Canada’s financial crime risk management model.” This change aims to enhance clarity in decision-making, redefine roles, and create more consistency within the team.
Davis’s LinkedIn profile listed his position as a special advisor to the Chief Risk Officer, which concluded this month after ten months. A TD spokesperson confirmed that his departure was due to the end of his contract. When asked for comment, Davis mentioned he is collaborating with a fintech company focused on Advanced AML and Financial Crime Technologies.
Before joining TD, Davis held the position of first vice president of financial crime risk management at Scotiabank and later served as executive vice president for internal data protection. Previously, he was the Global Chief Anti-Money Laundering Officer at Bank of Montreal and worked in various roles at USAA Financial Services, First Data/Western Union Financial Services, Capital One, and Bank of America.
Davis’s expertise lies in enhancing risk management and compliance frameworks, aiding financial institutions in adhering to regulations surrounding money laundering and financial crime prevention. He is recognized as one of North America’s leading experts in combating human trafficking.
TD is undergoing significant and expensive overhauls of its financial crime and risk management programs due to stringent requirements imposed by US authorities. The bank initially recruited Chicago-based Mazariegos from Bank of Montreal in November 2023. In addition, TD is expanding its team with numerous hires in money laundering and compliance roles, implementing new technologies, and restructuring its department to bolster its monitoring systems.
The organization plans to complete most of its restoration initiatives by the end of 2025, projecting a pre-tax financial impact of around US$500 million for the fiscal year.
