TD Bank has agreed to pay $3 billion in penalties after pleading guilty to violations of U.S. anti-money laundering federal laws.
Court documents reveal that from 2014 to 2023, TD Bank exhibited “long-term, pervasive, and systemic deficiencies” in its U.S. AML policies, procedures, and controls, failing to implement necessary remedial actions. Attorney General Merrick Garland stated, “By making its services convenient for criminals, TD Bank became one.”
For a decade, both regulators and the bank’s internal audit team continuously flagged issues with its transaction monitoring program, which remained “effectively static,” according to the Department of Justice (DoJ). Consequently, the bank did not automatically monitor all domestic ACH transactions, most check activities, and numerous other payment types. As a result, 92% of total transaction volume—amounting to $18.3 trillion—went unmonitored from January 2018 to April 2024. Even as the bank launched new offerings like the Zelle P2P service, it failed to implement appropriate monitoring measures.
This negligence led employees to label TD Bank as “convenient” for criminals. The DoJ reports that three money laundering networks successfully transferred over $670 million through TD Bank accounts from 2019 to 2023. One of these networks processed more than $470 million via large cash deposits into nominee accounts between January 2018 and February 2021. The operators incentivized employees with gift cards worth over $57,000 to ensure their transactions were processed.
The penalties include $1.8 billion allocated to the U.S. Justice Department, with the remainder designated for banking regulators and the Treasury Department’s Financial Crimes Enforcement Network. Additionally, TD Bank will appoint an independent compliance monitor for three years.
Garland noted, “Today, TD Bank became the largest bank in U.S. history to plead guilty to failures of the Bank Secrecy Act program and the first U.S. bank to plead guilty to conspiracy to commit money laundering. TD Bank prioritized profits over compliance with the law—a decision that is now costing the bank billions of dollars in penalties.”
TD Bank CEO Bharat Masrani remarked, “We have taken full responsibility for the failures of our U.S. program and are making the necessary investments, changes, and enhancements to fulfill our commitments. These failures occurred during my tenure as CEO, and I apologize to all our stakeholders.”