TD Bank, the tenth largest bank in the United States, and its parent company TD Bank US Holding Company have pleaded guilty to violations of the Bank Secrecy Act (BSA) and money laundering conspiracy. The plea agreement involves a penalty exceeding $1.8 billion to settle the Justice Department's investigation.
The bank admitted to conspiring to neglect an anti-money laundering (AML) program compliant with the BSA, failing to file accurate Currency Transaction Reports (CTRs), and laundering money. Attorney General Merrick B. Garland stated, "By making its services convenient for criminals, TD Bank became one."
The resolution is coordinated with several federal entities including the Board of Governors of the Federal Reserve Board, the Office of the Comptroller of the Currency, and Financial Crimes Enforcement Network. Deputy Attorney General Lisa Monaco emphasized that "crime doesn’t pay — and neither does flouting compliance."
Principal Assistant Attorney General Nicole M. Argentieri highlighted TD Bank's failure to update its AML compliance program over nearly a decade, noting that it made them an "easy target" for criminal networks. U.S. Attorney Philip R. Sellinger pointed out that TD Bank failed to monitor trillions of dollars in transactions due to oversight failures.
Court documents reveal systemic deficiencies in TD Bank’s AML policies from January 2014 through October 2023. Despite internal audits identifying concerns, TD Bank maintained a static transaction monitoring program during this period.
From January 2018 to April 2024, approximately $18.3 trillion in transaction activity went unmonitored due to inadequate coverage across various transaction types including ACH transactions and those involving high-risk countries.
These failures facilitated three money laundering networks which transferred over $670 million through TD Bank accounts between 2019 and 2023. Employees received gift cards as incentives from network operators who conducted large cash deposits into nominee accounts without detection.
As part of their plea agreement, TD Bank will forfeit over $452 million and pay a criminal fine exceeding $1.4 billion while retaining an independent compliance monitor for three years.
The case was investigated by IRS Criminal Investigation among other agencies with prosecution led by attorneys from the Criminal Division’s Money Laundering and Asset Recovery Section and Assistant U.S. Attorneys from New Jersey.