Miami-based TotalBank is suing its former CEO and his new employer for “raiding” TotalBank’s officers and allegedly misappropriating trade secrets.

Luis de la Aguilera left TotalBank in December to join Doral-based U.S. Century Bank. The 85-page complaint filed Tuesday in Miami-Dade Circuit Court against U.S. Century and de la Aguilera alleges he used his knowledge of TotalBank’s employee salaries and customer base to steal clients and key workers.