TD Bank Guilty Plea: Record Bank Secrecy Act Resolution Worth Over $1.8 Billion

TD Bank N.A. pleaded guilty to conspiring to fail to maintain a compliant anti-money laundering (AML) programme, fail to file accurate Currency Transaction Reports and launder money. The holding company pleaded guilty to causing those programme and reporting failures. The pleas form part of a coordinated resolution with the Federal Reserve Board, the Office of the Comptroller of the Currency and FinCEN.

What prosecutors found

According to court documents summarised by the Department, between January 2014 and October 2023 the bank had long-term, pervasive deficiencies in its US AML controls, while senior executives enforced a flat cost budget mandate. The bank did not automatically monitor all domestic ACH transactions, most cheque activity and numerous other transaction types, leaving 92% of transaction volume, about $18.3 trillion, unmonitored from 1 January 2018 to 12 April 2024. Three money laundering networks moved more than $670 million through TD Bank accounts between 2019 and 2023. More than two dozen individuals have been charged, including two bank insiders.

The penalties

• Justice Department: forfeiture of $452,432,302 and a criminal fine of $1,434,513,478.40, a total of $1,886,945,780.40, with a three-year independent compliance monitor. The criminal penalty reflects a 20% reduction for partial cooperation and remediation; the bank did not voluntarily disclose.
• FinCEN: a $1.3 billion penalty, which FinCEN described as the largest against a depository institution in Treasury and FinCEN history, and a four-year independent monitorship.

The Department will credit $123.5 million of the forfeiture towards the Federal Reserve's resolution. The IRS Criminal Investigation release confirms that IRS-CI, the FDIC Office of Inspector General and the Drug Enforcement Administration investigated the case.

What it means for financial institutions

The TD Bank guilty plea shows US authorities treating under-resourced compliance as a criminal matter at institutional level, not only a supervisory one. Banks with US operations should test whether transaction monitoring covers all products and payment channels, whether compliance budgets keep pace with growth and risk, and how quickly AML concerns are escalated to regulators and prosecutors.

Sources

• US Department of Justice: TD Bank Pleads Guilty to Bank Secrecy Act and Money Laundering Conspiracy Violations in $1.8B Resolution
• FinCEN: FinCEN Assesses Record $1.3 Billion Penalty against TD Bank
• IRS Criminal Investigation: TD Bank pleads guilty in $1.8b resolution