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# FinCEN Imposes Record $1.3 Billion Penalty on TD Bank in Multi-Agency AML Settlement
- URL: https://www.theglobalbanker.com/fincen-record-1-3-billion-penalty-td-bank-aml-settlement-3-1-billion/
- Published: 2024-10-10T11:34:00.000Z
- Updated: 2026-11-10T13:46:12.000Z
- Description: FinCEN has assessed a record $1.3 billion penalty against TD Bank for wilful BSA violations, part of a $3.1 billion multi-agency settlement including DOJ, OCC, and Federal Reserve actions.
- Author: TGB Editorial Team
- Tags: Regulations, Americas, #archive

The Financial Crimes Enforcement Network assessed a $1.3 billion penalty against TD Bank on 10 October 2024, the largest ever levied by FinCEN against a depository institution in US Treasury history. The penalty forms part of a multi-agency settlement totalling $3.1 billion that also encompasses a criminal resolution with the Department of Justice, a civil money penalty from the Office of the Comptroller of the Currency, and an action by the Federal Reserve.

TD Bank admitted to wilful failure to implement and maintain an adequate anti-money-laundering programme as required under the Bank Secrecy Act. 

#### SETTLEMENT BREAKDOWN

The settlement involves four US regulatory and law enforcement bodies. FinCEN's civil money penalty is $1.3 billion. The DOJ resolved its criminal case with a penalty of $1.43 billion plus a forfeiture of $452.4 million. The OCC separately assessed $450 million in civil money penalties. The Federal Reserve imposed a further $123.5 million. After credits between the agencies, total payments came to approximately $3.09 billion.

The DOJ resolution includes a three-year independent monitorship, and FinCEN's action imposes a four-year monitorship, under which an independent monitor reviews and reports on TD Bank's remediation of the identified AML failures. 

The OCC's $450 million penalty and the FinCEN action were announced on the same day, 10 October 2024, alongside the DOJ guilty plea and the Federal Reserve action. The Federal Reserve's $123.5 million penalty was imposed on the Canadian parent, Toronto-Dominion Bank, for failing to conduct adequate risk management and oversight of its US retail banking operations.

#### BANK SECRECY ACT REQUIREMENTS

The BSA requires financial institutions to file suspicious activity reports, conduct customer due diligence, and maintain a risk-based AML programme. FinCEN's findings indicated that TD Bank failed across multiple dimensions of this framework over a sustained period.