A $3 Billion Mistake
How TD Bank’s Compliance Gaps Opened the Door to Criminal Networks
📅 October 22, 2024
📅 October 22, 2024
On October 10, 2024, TD Bank made history—but not the kind any bank wants to be known for. The U.S. Department of Justice, along with the Office of the Comptroller of the Currency (OCC), and the Financial Crimes Enforcement Network (FinCEN), imposed a staggering more than $3 billion penalty on TD Bank for violating anti-money laundering (AML) laws. It’s the largest penalty ever imposed on a bank for failing to comply with the Bank Secrecy Act (BSA), and it’s a case that highlights just how costly non-compliance can be.
For over a decade, TD Bank turned a blind eye to its AML responsibilities, letting over $18 trillion in transactions slip through its systems without proper oversight. These lapses allowed money tied to drug trafficking, terrorist financing, and even human trafficking to flow through the bank undetected. As Deputy Secretary of the Treasury Wally Adeyemo bluntly said, “TD Bank did the opposite” of protecting the U.S. financial system. Instead, the bank’s failures provided a “fertile ground” for criminal activity to thrive.
This case serves as a wake-up call for financial institutions everywhere. TD Bank’s negligence spanned years, and it left the door wide open for illegal transactions to enter the U.S. financial system. As FinCEN Director Andrea Gacki said, “For over a decade, TD Bank allowed its AML program to languish,” making it an easy target for criminals—including its own employees. The consequences are clear: neglecting compliance can cost billions, damage reputations, and shake the very foundation of a financial institution.
TD Bank’s massive $3 billion in fines wasn’t just the result of a few missteps—it was caused by years of deep-rooted failures in its AML program. These problems ran across the entire bank, pointing to a culture that prioritized profit over compliance. Here’s what went wrong:
The penalties for TD Bank’s actions are not just financial—they’re also operational, with long-term effects on the bank’s ability to grow. Here’s a breakdown of the consequences:
Total Financial Penalty
TD Bank faces a total penalty and forfeitures from the DOJ, FinCEN, the OCC, and the Federal Reserve of more than $3.7 billion—the largest AML-related fine in U.S. history. Although the scale of the misconduct is significant, the record penalty is a coordinated effort by multiple government agencies to hold the bank accountable for its serious lapses in compliance.
Ongoing Monitoring and Compliance Remediation
As part of the settlement, TD Bank will be under close watch for the next few years. The bank must retain an independent compliance monitor for at least three years to oversee its AML program and ensure it’s making the necessary changes. TD Bank also agreed to cooperate with ongoing investigations into individuals involved in the misconduct, including both employees and external criminals.
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