TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations.  It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of Directors and senior leadership.  TD Bank’s priority on business — even illegal business — outweighed all interest in implementing and maintaining an effective BSA and AML compliance program.     ...

TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the Office of the Comptroller of the Currency (“OCC”).  Each regulator imposed civil penalties and remedial measures.  The Federal Reserve fined TD Bank $123.5 million for AML compliance violations.  The Federal Reserve also required TD Bank to...

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act (“BSA”) and money laundering violations. In addition to the financial settlement, TD Bank US Holding Company (TDBUSH) (together with TDBNA,...

Sam Finkelstein, an Associate at The Volkov Law Group, joins us for his first posting about TD Bank’s compliance failures. Sam can be reached at [email protected]. How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing out of a proposed $13.4...