In Regulatory Wrap for the week to October 18, Rob Mason discusses a record $3 billion fine against TD Bank for serious anti-money laundering (AML) failures.
In this Regulatory Wrap, we lay out the Department of Justice’s (DOJ) $3 billion fine against TD Bank for an accumulation of compliance failures related to the firm’s anti-money laundering (AML) program, marking it as the largest penalty ever imposed under the Bank Secrecy Act.
1. Over the course of six years, TD Bank failed to monitor a staggering $18.3 trillion of customer activity, which enabled money laundering networks to transfer hundreds of millions through accounts at the bank
2. Despite the fact that high-level staff was aware of these issues – including the bank’s future AML officer – no one made a move to intervene
3. The DOJ stated that the firm’s AML compliance program was “starved” of resources
4. Though TD Bank didn’t voluntarily disclose wrongdoing, it did receive partial credit for “strong cooperation,” which saved the firm from receiving an even steeper fine
5. The fine size levied for a system and controls failure combined with the emphasis on individual misconduct may indicate a new, intensified era of regulatory action
This Regulatory Wrap is brought to you by Global Relay’s Director of Regulatory Intelligence, Rob Mason.
We’ve seen regulators crack down on recordkeeping noncompliance time and time again, thought the DOJ’s recent fine against TD Bank seems to foretell regulatory action to come. Whether it’s for AML infrastructure, record retention, or surveillance data – a lacking commitment to compliance will be sure to land firms in hot water.
