TD Bank N.A. and its parent company, TD Bank US Holding Company, have pleaded guilty and agreed to pay over $1.8 billion to settle a Justice Department investigation into violations of the Bank Secrecy Act and money laundering. This makes TD Bank the largest bank in U.S. history to plead guilty for such failures.
The investigation revealed that TD Bank failed to maintain an adequate anti-money laundering program, failed to file correct Currency Transaction Reports, and allowed money laundering activities to occur. Attorney General Merrick B. Garland stated that the bank prioritized profits over legal compliance, resulting in significant penalties.
Deputy Attorney General Lisa Monaco emphasized that TD Bank’s failure over many years to properly fund and update its compliance program created vulnerabilities that were exploited by criminals. The bank’s internal communications noted that its lapses made it an “easy target” for illicit activities.
From 2014 through 2022, TD Bank’s transaction monitoring program did not address known issues or adapt to new risks. As a result, a staggering 92% of its transaction volume went unmonitored during a specific period, amounting to approximately $18.3 trillion.
The plea agreement includes a forfeiture of over $452 million, along with a criminal fine of more than $1.4 billion, totaling nearly $1.9 billion. TD Bank will also appoint an independent compliance monitor for three years and enhance its anti-money laundering program.
The investigation involved multiple agencies, including the IRS Criminal Investigation and the Federal Deposit Insurance Corporation, and emphasized the government’s commitment to hold financial institutions accountable for compliance failures.