TD Bank N.A. and its parent company, TD Bank US Holding Company, have entered guilty pleas in a case involving significant violations of the Bank Secrecy Act and money laundering, agreeing to pay over $1.8 billion in penalties. The Justice Department’s investigation revealed that TD Bank failed to maintain an adequate anti-money laundering program and inaccurately filed Currency Transaction Reports.
TD Bank N.A. was found guilty of conspiring not to maintain a proper AML program and of laundering money, while its parent company was guilty of enabling these failures. This resolution is part of a coordinated effort involving multiple regulatory bodies, including the Federal Reserve Board and the Financial Crimes Enforcement Network.
Attorney General Merrick B. Garland criticized TD Bank for prioritizing convenience and profits over lawful practices, marking the bank as the largest in U.S. history to plead guilty to such offenses. Deputy Attorney General Lisa Monaco noted that this case serves as a critical lesson for banks about the importance of compliance.
The investigation revealed long-standing deficiencies in TD Bank’s AML policies that were ignored despite repeated warnings. Senior executives enacted budget constraints that limited necessary updates to their compliance programs, allowing substantial amounts of illicit transactions to go unmonitored.
Between 2014 and 2023, TD Bank’s oversight failures permitted the transfer of significant amounts of money through the bank, including transactions associated with international drug trafficking. Specific schemes involved large cash deposits and the misuse of bank accounts, with TD Bank employees directly involved in facilitating these actions.
As part of their plea agreement, TD Bank will forfeit over $452 million and pay a criminal fine, totaling nearly $1.9 billion. The bank is also required to appoint an independent compliance monitor for three years and enhance its AML compliance measures.
The Justice Department noted that although TD Bank did not initially disclose its wrongdoing, it did cooperate with the ongoing investigation, leading to a partial reduction in penalties. The case was investigated by various federal agencies and is part of a broader effort to combat organized crime linked to drug enforcement operations.