The Weekly Alpha - Canadian AML & Financial Crime Briefing
October 09, 2026
The Alpha Brief
This week brought institutional control failures, a changing approach to digital assets, and investigations focused on the financial networks behind criminal activity.
Control Failures Inside Trusted Systems
American Express, TD Bank and Canada’s federal security-screening process exposed three different control problems. The OCC found that American Express had systemic weaknesses across its BSA/AML program, while former TD employee Gerardo Aquino admitted using his position to open fraudulent accounts, issue debit cards and move millions of dollars to Colombia. In Canada, the arrest of a NATO intern who had previously been found to have committed fraud during a CBSA hiring process raised separate questions about how information is shared and assessed before security clearances are granted.
Digital-Asset Policy Takes Different Paths
Canada is building digital-asset tracing into the proposed Financial Crimes Agency, with cryptocurrency analysis, blockchain tracing and digital forensics expected to form part of its investigative capability. FinCEN, meanwhile, withdrew proposed rules covering unhosted wallets and convertible virtual currency mixing after reviewing public comments and reconsidering its approach to digital-asset regulation. The two developments reflect different policy tools, with Canada emphasizing investigative capability while FinCEN steps back from two proposed transaction-level regulatory measures.
Following Financial Networks Across Crime Types
The Hamas fundraising case and INTERPOL’s environmental-crime operation both show financial and corporate intelligence being used to map networks extending beyond the underlying offence. U.S. prosecutors allege that purported charitable campaigns and international transfers helped raise more than US$1.7 million for Hamas, while INTERPOL traced payments, companies, properties and corporate links associated with environmental crime across multiple jurisdictions. In both cases, investigators focused on the people, entities and financial relationships supporting activity across borders.
This Week in AML
OCC assesses $350 million civil money penalty against American Express
The OCC fined American Express National Bank $350 million and ordered remediation after finding its BSA/AML program was not reasonably designed for the bank's risk profile. The regulator cited inadequate staffing and expertise, systemic internal-control gaps, weak independent testing and training, an ineffective risk assessment that underweighted credit and charge-card risks, and weaknesses in CDD and CIP. Those failures contributed to breakdowns in suspicious-activity monitoring and reporting, including approximately US$13 billion of suspected trade-based money laundering activity that the bank did not timely identify, evaluate and sufficiently report over roughly a decade. The Federal Reserve issued a concurrent enterprise-wide enforcement action against American Express Company.
Office of the Comptroller of the Currency
Digital-asset tracing will be key priority for new financial-crimes agency, deputy minister says
Canada’s proposed Financial Crimes Agency (FCA), expected to launch following the passage of Bill C-29, will prioritize digital-asset tracing to combat organized crime’s use of cryptocurrency for laundering proceeds of crime. Deputy Minister Rob Stewart emphasized the need for expertise in analyzing crypto transactions as criminals convert cash to virtual currencies and move funds across borders. The FCA will initially include RCMP personnel and focus on addressing gaps identified by FATF in prosecuting money laundering and supervising high-risk sectors like virtual currency exchanges.
The Globe & Mail
Coordinated Arrests and Charges Dismantle Hamas Terror Finance Network Raising Funds from the United States
The U.S. Justice Department announced coordinated arrests and charges targeting an alleged Hamas fundraising network operating across the United States and France. Prosecutors allege that Gaza-based Hamas member Saleem Alzaq raised more than US$1.7 million since 2020 through purported charitable campaigns, with associates helping collect and transfer funds internationally. U.S. defendants allegedly contributed nearly US$155,000 to the network, including approximately US$94,000 from Abdel Adhami, US$11,000 from Omar Adhami and almost US$50,000 from Raed Yousef, with some transfers allegedly concealed through intermediaries and wire payments. Charges include material support, money laundering, wire fraud and sanctions-related offences; the allegations have not been proven in court.
U.S. Department of Justice
Public safety minister admits security 'gaps' after NATO intern arrest
Public Safety Minister Gary Anandasangaree acknowledged “gaps” in Canada’s security screening process after a Canadian NATO intern was arrested in Belgium on espionage and criminal-organization charges. The case has drawn scrutiny because the suspect, identified by media as Biwei Zhang, had previously committed fraud during a Canada Border Services Agency hiring process by applying under two names, yet later obtained a federal security clearance. Anandasangaree said more than 200,000 screenings are conducted annually and promised lessons from the case, while officials said Secret-level screening now includes a mandatory internet inquiry. Treasury Board officials also identified weaknesses in information-sharing between departments, including personnel records.
National Post
FinCEN Announces Withdrawals of Proposed Digital Asset Related Rules
FinCEN announced the withdrawal of two proposed rules targeting digital assets: one imposing recordkeeping, verification, and reporting requirements on convertible virtual currency transactions involving unhosted wallets, and another proposing a special measure on convertible virtual currency mixing as a primary money laundering concern. This action aligns with the Trump Administration’s deregulatory agenda and aims to ensure digital asset regulations remain fit-for-purpose. The withdrawal follows consideration of public comments.
FinCEN
Former TD Bank Employee Pleads Guilty to Accepting Bribes, Laundering $4.8 Million to Colombia
A former TD Bank employee has pleaded guilty to accepting bribes and laundering more than US$4.8 million to Colombia by exploiting his position inside the bank. Gerardo Aquino admitted that between April 2022 and November 2023 he opened fraudulent accounts, issued hundreds of debit cards to co-conspirators and unblocked cards TD Bank had restricted for potential fraud; 86 accounts opened using the same Miami commercial address moved more than US$3 million. Aquino received more than US$8,000 in bribes paid in cash and through a peer-to-peer payment network. He pleaded guilty to money laundering conspiracy and receipt of bribes by a bank employee and is scheduled to be sentenced on March 23, 2027.
U.S. Department of Justice
233 arrested in environmental crime crackdown in Latin America and Caribbean
INTERPOL coordinated Operation Madre Tierra VIII across nine Latin American and Caribbean countries, leading to 233 arrests, more than 330 cases, over 1,000 recovered animals and the identification of 60,000 hectares of illegally cleared forest. Investigators also traced financial and corporate links behind environmental crime networks, including payments, companies and properties used to conceal activity across borders. Building on a 2025 Colombian deforestation investigation, INTERPOL identified links to an additional 161 companies and 65 individuals across several continents, with alleged permit fraud, shell companies and foreign investment mechanisms. Colombian raids resulted in 16 arrests and further digital evidence seizures.
INTERPOL
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