Last month, a bank with 164 locations in Florida admitted that its institutional scheme included conspiring to launder hundreds of millions in dirty money from high-ranking money launderers serving drug cartels. The sin was so bad that some experts believe the bank should have lost its US license and senior executives should be in jail.

Instead, TD Bank got a $3 billion slap in the face that shareholders will pay. Yes, $3 billion is a lot of money, but not for an international organization that gives life to the cartels by laundering the proceeds of fentanyl and other illicit drug sales that kill tens of thousands of Americans every year.

Dirty banks and other money laundering agents play an essential role in organized crime. They convert mountains of cash into bank balances that create businesses disguised as legitimate concerns. Corruption runs deep. For example, former Honduran President Juan Orlando Hernandez is now serving a 45-year US prison sentence for his role in selling his nation’s rights to Colombian and Mexican cartels that used Honduras as a transshipment point for thousands of tons of deadly drugs intended for the United States of America.

It doesn’t have to be this way.

As a federal agent, I spent five years undercover as a money launderer for drug cartels moving tens of millions in dirty money. We gathered evidence of their crimes and their crooked bankers. I assure you that we know how to take action against dirty banks and bankers. We just didn’t have the will to do it.

Take the case of Da Ying Sze, also known as David. Beginning in 2016, he began laundering about $470 million in drug money at TD Bank, according to federal court documents.

Underworld money brokers like David buy currency from drug dealers and sell it in the form of checks and wire transfers to dollar-hungry businessmen around the world. Money brokers like David earn commissions from both traffickers and buyers of checks and wire transfers. As a hedge money broker, I made more than 10% when I did this type of swap.

Just months after his arrest, US authorities offered David a plea deal. The document stated that he only faced a maximum of 10 years in prison because, among other things, he “assisted the authorities and accepted a timely plea. “In law enforcement parlance, he rolled over his co-conspirators and said it all.

The government investigation of TD Bank and its employees uncovered far more laundering than the $470 million in cash dumped on their homes by David and his cohorts. TD Bank provided VIP services to two other money laundering organizations. In one case, $120 million in cash was laundered for a group that claimed to control the precious metals and jewelry businesses, well-known laundering fronts. In another, $39 million was moved by a separate laundering ring from Florida to Colombia with the help of five corrupt TD Bank employees. This group moved bank balances from personal and business accounts in Florida through approximately 195,000 cash withdrawals at ATMs in Columbia.

Court records the government filed against TD Bank list many email exchanges about David’s accounts from the bank’s front-line employees, including branch managers. They all respond to the awareness of what is happening.

Employee 1: How is that not money laundering?

Employee 2: Oh, it’s 100%.

Can it get any more obvious than that?

Bank employees filed numerous internal alerts about hundreds of millions of dollars deposited by David and his friends, according to court records. Those alerts, which eventually reached senior TD Bank managers, prompted TD Bank to file formal suspicious activity reports with the government. Despite the best efforts of lower-level TD Bank employees, those reports were never filed.

There is little reason to believe that upper management did not know what was going on. Driven by a business plan of growth and expansion, they did nothing on purpose. How the behavior of those works bank executives don’t rise to the level of conspiracy to commit money laundering, a crime punishable by 20 years in prison and a maximum fine equal to half the value of what David and others laundered?

Any well-meaning senior bank executive would have spotted other red flags. David’s accounting records claim that his businesses were concerns in the clothing and fashion industry in the Northeastern United States, an industry well known to not receive a million dollars a day in foreign exchange in the normal course of business. Second, his cash deposits were quickly withdrawn from each account through domestic and international transfers, many to China, a well-known pattern consistent with money laundering. He also issued checks and received bank checks payable to third parties, in a pattern consistent with North American black money markets dominated by Chinese nationals for the past five years or more.

In addition to his other illegal activity, David’s plea agreement states that he bribed bank employees with improper gifts totaling approximately $3.73 million. Curiously, a subsequent Justice Department press release said only that he bribed officials with $57,000 in gift cards. We can only hope that law enforcement will soon tell us who received the additional $3.6 million in bribes.

One of TD Bank’s main defenses was that it used and obsolete inferior transaction monitoring software. The management officials were able to tell that he was not their person blame that David laundered almost half a billion in foreign currency at their bank. Outdated software was the bad one, they said. The bank, however, didn’t need sophisticated software to see what was going on. It was obvious.

Separately, we need to look more closely at what the government knew, or should have known, before David decided to tell all. The bank filed 584 currency transaction reports, which are required for any foreign currency deposit, withdrawal, transfer, payment or exchange over $10,000. The reports allegedly alerted the government to more than $400 million in cash deposits by David and his cohorts, an obvious red flag. Why didn’t the sirens go off at the Internal Revenue Service and other US agencies? Is someone monitoring and analyzing transaction reports or going into a black hole? This is a question I’ve heard from many anti-money laundering professionals.

Here’s an even better and less expensive way for law enforcement to identify cartel money laundering. Drug users do not routinely buy fentanyl and meth on the street with cryptocurrency. Cash remains king. Crypto has an emerging supporting role in drug money laundering, but is dwarfed by the cash handled by the many hundreds of Davids dropping cash at bank vaults. For years we have urged governments around the world to have a reverse audit trail, meaning they should identify the amount of US currency repatriated each month to their respective federal central banks and trace it back. My first public call for governments to conduct these audits was published in the New York Times 14 years ago. A reverse audit would identify the banks from which the central banks received that cash. From there, the government can use the Patriot Act to legally determine which banks and account holders have given central banks large sums of cash. It’s simple.

Account managers should also swear an affidavit in response to key questions about any account where at least $5 million is deposited in a year, which I have proposed to governments and industry professionals in the past. That way, the account managers who brought David’s accounts and the accounts of other money laundering networks would have been more easily prosecuted for their intentional misrepresentations about what they knew and when they knew it.

In 2019, we provided the global law enforcement and regulatory communities a detailed proposal outlining how nations could establish a multinational consortium of task forces, led by the US, to continuously identify and track the top 10 money laundering threats on the planet. I’ve outlined an eight-point process they could follow to achieve this goal. I’m still holding my breath and hope to get feedback from agencies on the plan one day.

If we are serious about identifying and prosecuting real money launderers and corrupt bank officials, we shouldn’t worry so much about every little money laundering risk that might exist. Instead, we need to keep prosecutions simple, deal with the real problems and put corrupt bank managers, executives and lawyers in jail. They facilitate the success of the cartels and are just as responsible for fentanyl and other drug-related deaths as those who sell lethal drugs to your children. Without money laundering professionals, traffickers cannot hide and dirty launderers cannot create a veil of plausible deniability. Stop the empty excuses like “Oh, this would never have happened if we had updated our software.” Yes, correct.

Robert Mazur, a 27-year-old federal agent, is a court-certified expert on money laundering issues in both the US and Canada. He is the New York Times bestselling author of “The Infiltrator,” a memoir about the first half of his life undercover as a money launderer in Pablo Escobar’s Medellin cartel, and was executive producer of the film of the same name . His new book, “Betrayal,” is a memoir about his last undercover assignment, a deep dive into Colombia’s Cali Cartel and the Panamanian underworld that nearly cost him his life. He is the President of KYC Solutions, a company that provides global speaking, training, consulting and expert witness services.