TD Bank N.A. and its parent company, TD Bank US Holding Company, have entered guilty pleas today, agreeing to pay over $1.8 billion in penalties following a Justice Department investigation into breaches of the Bank Secrecy Act (BSA) and money laundering.
TD Bank N.A. admitted to conspiring to neglect an anti-money laundering (AML) program compliant with BSA standards, to inaccurately file Currency Transaction Reports (CTRs), and to engage in money laundering activities. Concurrently, TD Bank US Holding Company acknowledged responsibility for the AML compliance failures at its subsidiary.
This guilty plea is part of a coordinated resolution alongside various regulatory bodies, including the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Financial Crimes Enforcement Network.
Attorney General Merrick B. Garland remarked on the case, stating that by facilitating criminal activity through lax controls, TD Bank has set a historical precedent as the largest bank to plead guilty to such violations. He emphasized that decisions prioritizing profit over legal compliance have led to substantial financial penalties and stressed the ongoing nature of the investigation, indicating that no individuals involved are exempt from scrutiny.
Deputy Attorney General Lisa Monaco noted the serious shortcomings of TD Bank’s compliance program, calling today’s penalties a stark reminder that noncompliance will incur severe consequences. She encouraged bank officials nationwide to use this case as a warning against neglecting compliance protocols.
TD Bank’s failures to maintain an effective AML program spanned nearly a decade, leaving the bank vulnerable to criminal exploitation. Internal communications revealed that TD Bank had recognized its deficiencies, describing itself as an “easy target” for illicit actors. U.S. Attorney Philip R. Sellinger highlighted that the institution chose expediency and growth over fulfilling its legal duties, resulting in the unchecked movement of vast sums associated with money laundering enterprises, including those linked to international drug trafficking.
Court documents indicate that from January 2014 to October 2023, TD Bank’s AML policies exhibited systemic flaws, with senior management enforcing budget constraints that limited necessary expenditures for compliance despite rising profits and risks.
Between January 2018 and April 2024, the bank failed to monitor a staggering 92% of domestic automated clearinghouse transactions, amounting to approximately $18.3 trillion in activity. This negligence allowed several money laundering operations to transfer around $670 million through TD Bank accounts.
As part of the plea agreement, TD Bank has committed to forfeit $452 million and pay a criminal fine totaling over $1.4 billion. The agreement also mandates the retention of an independent compliance monitor for three years and requires enhancements to its AML program.
The Justice Department reached this settlement after considering the serious nature of the offenses, as TD Bank’s lapses made it a preferred institution for multiple money laundering organizations. Although the bank did not voluntarily disclose its wrongdoing, it received some leniency for cooperating during the investigation.
The case has drawn attention from various enforcement agencies, including the IRS Criminal Investigation and the Drug Enforcement Administration. The prosecution was led by attorneys from the Criminal Division’s Money Laundering and Asset Recovery Section along with Assistant U.S. Attorneys from New Jersey.
This case forms part of broader efforts under the Organized Crime Drug Enforcement Task Forces initiative, designed to tackle high-level criminal organizations threatening national integrity.