TD Bank N.A. (TDBNA) and its parent company, TD Bank US Holding Company (TDBUSH), pleaded guilty to violating the Bank Secrecy Act (BSA) and money laundering charges. As a result, the bank agreed to pay over $1.8 billion in penalties. This settlement represents a significant TD Bank money laundering penalty and resolves a Justice Department investigation into the bank’s failure to meet anti-money laundering (AML) requirements, including lapses in filing accurate Currency Transaction Reports (CTRs).

TD Bank’s Admission of Guilt and Money Laundering Penalty

TDBNA admitted to conspiring to neglect its AML program and launder money. Meanwhile, TDBUSH pleaded guilty to causing TDBNA’s BSA compliance failures. As part of the resolution, the penalties stem from coordination with the Federal Reserve Board (FRB), the Office of the Comptroller of the Currency (OCC), and the Financial Crimes Enforcement Network (FinCEN).

“By making its services convenient for criminals, TD Bank became one,” said Attorney General Merrick B. Garland. He stressed that TD Bank is now the largest U.S. bank to plead guilty to these charges. Additionally, Garland highlighted that the investigation remains active.

Impact of the Money Laundering Penalty

“Today’s guilty plea offers an unmistakable lesson: crime doesn’t pay—and neither does flouting compliance,” said Deputy Attorney General Lisa Monaco.

The charges arose from long-term deficiencies in TD Bank’s AML program, spanning from January 2014 to October 2023. Although the bank received warnings, it failed to address significant risks. Consequently, the bank restricted compliance funding, leaving it vulnerable to money laundering activities involving trillions of dollars.

“These failures allowed corrupt bank employees to help a criminal network launder tens of millions of dollars,” stated Principal Assistant Attorney General Nicole M. Argentieri.

Money Laundering Failures and Negligence

US Attorney Philip R. Sellinger for the District of New Jersey described TD Bank’s actions as willful neglect. Specifically, he noted, “The bank willfully failed to monitor trillions of dollars in transactions,” allowing hundreds of millions of dollars to flow through from money laundering networks.

From 2018 to 2024, TD Bank failed to monitor $18.3 trillion in transactions, including automated clearinghouse (ACH) transactions and other high-risk activities. This oversight allowed over $670 million in money laundering through TD Bank accounts. Furthermore, the bank allowed suspicious transactions to proceed unreported.

TD Bank’s $1.8 Billion Penalty and Future Compliance Plans

As part of the plea agreement, TD Bank will forfeit $452 million and pay a criminal fine exceeding $1.4 billion. Additionally, the bank must retain an independent compliance monitor for three years to improve its AML program. TD Bank also reached agreements with the FRB, OCC, and FinCEN, with $123.5 million credited toward the FRB’s resolution.

Although TD Bank partially cooperated in the investigation, it only received a 20% penalty reduction. This was due to delays in reporting AML concerns. The Justice Department noted that these delays contributed to the substantial TD Bank money laundering penalty.

Investigation and Prosecution

The IRS Criminal Investigation Division, the FDIC Office of Inspector General, and the DEA led the investigation. Additionally, law enforcement agencies, including the Morristown Police Department and US Customs and Border Protection, provided support.

Prosecutors from the Justice Department’s Criminal Division and US Attorneys from New Jersey managed the case. The Bank Integrity Unit, which addresses BSA and AML violations, led the investigation. Importantly, this investigation is part of the Organized Crime Drug Enforcement Task Forces (OCDETF) initiative, which targets major criminal organizations in the U.S.

TD Bank CEO’s Statement on the Penalty

“We take full responsibility for the failures of our U.S. [anti-money laundering] program and are making the necessary investments, changes, and improvements,” said Bharat Masrani, group president and CEO of TD Bank Group. “This is a difficult chapter in our Bank’s history. These failures happened on my watch as CEO, and I apologize to all our stakeholders.”