TD Bank

As of September 2026: The independent monitor and the OCC asset cap remain in place, and TD's remediation milestones, including a suspicious-activity lookback, run through 2027. Verify the current status of the cap before citing it.

Also known as: TD Bank guilty plea · TD Bank N.A. BSA case.

What happened?

On October 10, 2024, TD Bank, N.A. became the first US bank to plead guilty to conspiring to commit money laundering. The plea was part of a US$1.8 billion Department of Justice resolution, and the total penalty across four agencies was about US$3.09 billion.

Prosecutors said the problem was not one bad deal but a failure of oversight. DOJ said TD kept its transaction monitoring “effectively static” from 2014 through 2022, and intentionally did not automatically monitor most check activity, domestic ACH transfers and other transaction types. The result: 92% of total volume, about US$18.3 trillion, went unmonitored from January 1, 2018 to April 12, 2024. DOJ also said the bank had chosen to underfund and understaff its AML program in favor of a “flat cost paradigm” and the customer experience. Into that gap came three laundering networks, which moved more than US$670 million through TD accounts between 2019 and 2023.

Which techniques did it use?

None of the methods were exotic, which is the point. One network processed more than US$470 million between January 2018 and February 2021 through large cash deposits into nominee accounts, and its operators gave TD employees gift cards worth more than US$57,000 to make sure the transactions kept being processed. In another scheme, funds deposited in the US were quickly withdrawn at ATMs in Colombia, and five TD employees conspired with the network by issuing dozens of ATM cards, laundering about US$39 million.

The building blocks are the ones described in the techniques section: large cash deposits, accounts used to pass money through, and cards handed to people who are not the account holders. In the government’s account, the bank’s failure to monitor left those ordinary methods unchallenged, and insiders were bribed to help.

How was it found?

DOJ’s case against the bank centered on why its monitoring had not surfaced the activity. Banks are the main source of the suspicious activity reports that launder-catching depends on, so when a bank does not file them, investigators often reach the crime from the other side and the bank’s failures come to light afterwards.

What was the outcome?

The bank paid about US$3.09 billion combined: roughly US$1.8 billion to DOJ, US$1.3 billion to FinCEN, US$450 million to the OCC and US$123.5 million to the Federal Reserve. FinCEN’s penalty was the largest it had imposed on a depository institution.

The non-monetary terms may matter more. The OCC placed an asset cap on TD’s US retail banking, the first cap on a bank this size since Wells Fargo in 2018, limiting how far the bank can grow. Guidepost Solutions was approved as independent monitor in February 2025. TD projected roughly US$1 billion in remediation spending over two years, and its own disclosures show milestones running through 2026 and 2027, including a review of past transactions for suspicious activity.

What were the warning signs?

The TD record is unusually useful because the red flags are plain. Compliance teams and examiners can study them as a checklist of what a healthy monitoring program should catch.

• Insiders receiving gifts from customers. More than US$57,000 in gift cards went to bank employees from one network to keep transactions flowing. A customer who rewards staff is a conflict-of-interest signal, not a courtesy.
• Cards issued in bulk to people who are not the account holders. Five insiders issued dozens of ATM cards that were used to withdraw about US$39 million in Colombia.
• Large cash deposits into nominee accounts. More than US$470 million passed through such accounts in one network, far beyond anything ordinary retail customers generate.
• Funds withdrawn quickly in another country. Money deposited in the US and pulled out at ATMs in Colombia is a standard flag on the money mule pattern.
• Very large blind spots. The scale of unmonitored activity, 92% of volume or about US$18.3 trillion, is itself the warning: a bank that cannot see most of its flows cannot file the reports that regulators depend on.

What changed afterwards?

The plea broke an assumption. For years, the largest banks had been seen as too important to convict, which is why HSBC in 2012 received a deferred prosecution agreement instead of a plea. TD showed that a major bank could face a conviction. The asset cap added a penalty that grows over time, unlike a one-off fine.

Whether that changes behavior industry-wide is less certain. Compliance is still a cost centre, monitoring systems still produce more alerts than analysts can review, and the penalty arrived a decade after the conduct began. The remediation lookback may be the most useful legacy: reports filed on past transactions can feed new investigations of the people who used the bank. See the detection overview for how monitoring and reporting are meant to work.

First published September 21, 2026 · Last updated September 21, 2026 · Legal statuses current as of September 2026