TD Bank Achieves Historic Milestone as First American Bank to Admit Guilt in Money Laundering Conspiracy

TD Bank, one of the largest financial institutions in the U.S., has agreed to pay a record $3 billion penalty, the largest ever under the Bank Secrecy Act, after pleading guilty to felony charges. The bank is the largest in U.S. history to plead guilty to Bank Secrecy Act program failures and the first to admit to conspiracy to commit money laundering.
The Justice Department emphasized the bank’s compliance failures, which created an environment where financial crime thrived.
TD Bank Pleads Guilty to Money Laundering and Bank Secrecy Act Violations
U.S. Attorney General Merrick B. Garland announced in Washington D.C. on Thursday that TD Bank had entered a guilty plea to multiple felony charges, including conspiring to violate the Bank Secrecy Act and committing money laundering.
In his statement, Garland confirmed that TD Bank agreed to a criminal penalty of $1.8 billion, and combined with civil enforcement actions, the total penalty imposed against the bank would be approximately $3 billion. He noted that the resolution included “the largest-ever penalty under the Bank Secrecy Act and the first time the Justice Department has assessed a daily fine against a bank.” Garland stressed:
TD Bank created an environment that allowed financial crime to flourish. By making its services convenient for criminals, it became one.
Garland explained that TD Bank admitted to failing to maintain an adequate anti-money laundering program from January 2014 to October 2023. During this period, it did not monitor $18.3 trillion in customer activity, allowing three money laundering networks to transfer over $670 million through its accounts. One scheme involved five bank employees. The bank’s automated transaction monitoring system, designed to flag suspicious activity, was deliberately ineffective. Senior executives, including the future chief anti-money laundering officer, were aware of the system’s deficiencies but failed to address them.
As part of the agreement, TD Bank will undergo significant reforms, including restructuring its compliance program. Noting that TD Bank is the 10th largest bank in the U.S., Garland further emphasized:
Today, TD Bank became the largest bank in U.S. history to plead guilty to Bank Secrecy Act program failures and the first U.S. bank in history to plead guilty to conspiracy to commit money laundering.
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