The Office of the Comptroller of the Currency issued a cease and desist order and assessed a $450 million civil money penalty against TD Bank, N.A. and TD Bank USA, N.A. on 10 October 2024 for systemic deficiencies in the bank's Bank Secrecy Act and anti-money laundering compliance programme.
The action was co-ordinated with concurrent actions by the Department of Justice, the Federal Reserve and FinCEN. Simultaneously, the Department of Justice secured a $1.89 billion criminal resolution — comprising forfeiture and a criminal fine — after TD Bank entered a guilty plea to conspiracy to commit money laundering, which the DOJ said made it the largest US bank to plead guilty to BSA/AML violations. The Financial Crimes Enforcement Network assessed $1.3 billion and the Federal Reserve imposed $123.5 million. Canada's FINTRAC had separately fined TD C$9.185 million in May 2024. Combined penalties across all authorities exceeded $3 billion.
ASSET CAP
Beyond the monetary penalties, the OCC's order included a restriction on asset growth. The measure caps the combined assets of TD's two US bank charters at about $434 billion, their level at 30 September 2024, until regulators are satisfied that its compliance infrastructure has been sufficiently remediated. The OCC also required the boards of the two banks to certify in writing that appropriate resources and staffing had been allocated to the remediation before paying dividends or making other capital distributions, and mandated both a third-party assessment of the BSA/AML programme and a suspicious activity review lookback covering a defined historical period.
Regulators indicated the deficiencies were not isolated process failures but reflected systemic weaknesses embedded across the bank's US operations.
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