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...

The Treasury Department’s Office of Foreign Asset Control had another consistent year – not a big year but continued adherence to its enforcement program. At the end of the year, OFAC announced a settlement with TD Bank for $115,000 for two separate sanctions violations. In the first, TD Bank illegally processed nearly 1,500 transactions that violated US sanctions against North Korea.  Interestingly, it does not...