Stuart Davis Departs TD Bank Following Ten-Month AML Advisory Role Amid Historic U.S. Probe

Stuart Davis, a prominent expert in financial crimes and anti-money laundering (AML), has left Toronto-Dominion Bank (TD) after completing a 10-month advisory contract. Davis, who joined the bank last summer, was brought in as a special adviser to chief risk officer Ajai Bambawale during a period of intense regulatory scrutiny surrounding TD’s involvement in a historic U.S. money laundering investigation.

At the time of his appointment, TD stated that Davis’s position would be temporary and that he would be supporting “a range of strategic initiatives.” Davis, widely regarded as a senior figure in the AML industry, has spearheaded advanced compliance and financial crime projects across both Canada and the United States. His tenure at TD coincided with one of the most turbulent periods in the bank’s history.

TD confirmed Davis’s departure to The Globe and Mail. Speaking to the same publication, Davis shared that he is currently engaged with fintech companies, focusing on “advanced AML and financial crime technologies.”

Davis previously held high-ranking compliance and risk roles at Scotiabank and Bank of Montreal and is well known for his expertise in overhauling and rebuilding financial crime compliance programs.

His recruitment by TD came as the bank found itself under investigation in the United States for serious breaches of anti-money laundering regulations. In a significant development last year, TD pleaded guilty to conspiracy to commit money laundering. The plea marked a watershed moment, making TD the largest bank in U.S. history to admit guilt in violating a federal AML law. The penalties were severe: a $3-billion fine and an asset cap placed on its U.S. operations.

Davis’s departure comes amid broader structural changes to TD’s financial crime team. In January, Jacqueline Sanjuas took over as the bank’s chief AML officer, succeeding Herb Mazariegos, who had joined TD in November 2023 from Bank of Montreal. Last week, Sanjuas announced a sweeping leadership reshuffle, with three senior executives departing the institution. These include Sohana Inderlall, vice-president of risk and business control programs; Caitlin Riddolls, vice-president of risk oversight for Canadian banking; and Rick Hamilton, vice-president of data and model management. According to Sanjuas, all three are “pursuing other opportunities.”

Explaining the restructuring, Sanjuas said the changes are aimed at “simplify[ing] the financial crime risk operating model in Canada.” She emphasized that the initiative is focused on enhancing decision-making processes, redefining team responsibilities, and establishing more consistency across the financial crime division.

TD is now undertaking a major overhaul of its AML and compliance infrastructure. The bank has already onboarded dozens of new staff members and implemented new technological systems. Most of the remediation work is expected to be completed by late 2025. For the current fiscal year, TD has projected approximately US$500 million in pre-tax costs associated with these efforts.

By fLEXI tEAM