Toronto-Dominion Bank (TD Bank Group) is headquartered in Toronto, Canada, and is one of Canada’s largest financial institutions. Its US retail banking subsidiary, TD Bank N.A., operates a substantial branch network in the United States.
At the time of its criminal resolution, the US Department of Justice described TD Bank N.A. as the 10th-largest bank in the United States - this was not a minor regional lender.
On 10 October 2024, TD Bank N.A. pleaded guilty to criminal offences: conspiring to fail to maintain an anti-money-laundering programme compliant with the Bank Secrecy Act, failing to file accurate Currency Transaction Reports, and conspiring to launder monetary instruments. Its US holding company pleaded guilty to related charges at the same time.
The scale and duration
The failures were not a single lapse - they ran for close to a decade. Between 2014 and 2023, TD Bank failed to adequately update its Anti-Money Laundering (AML) compliance programme despite known risks; from 2014 through 2022, no new detection scenarios were added to its transaction-monitoring system despite recognised gaps and new products being introduced. The Justice Department found that these failures let three separate money-laundering networks move more than US$670 million through TD accounts between 2019 and 2023 - one network with the direct help of five TD Bank employees.
The penalty
TD Bank agreed to:
- Forfeit approximately US$452.4 million
- Pay a criminal fine of approximately US$1.434 billion
- Combined DOJ financial penalties of roughly US$1.8 billion
- Accept an independent compliance monitor
- Substantially rebuild its AML programme
The Justice Department called it the largest penalty ever imposed under the Bank Secrecy Act, and the first time a US national bank had pleaded guilty to a conspiracy to launder money.
Individual accountability, alongside institutional accountability
This was not just a corporate fine standing in for individual wrongdoing. In January 2026, former TD Bank employee Wilfredo Aquino pleaded guilty to conspiring to launder monetary instruments after helping move hundreds of millions of dollars through TD accounts.
Still operating
Despite a criminal guilty plea, nearly a decade of documented AML failures, its own employees implicated in laundering, and close to $2 billion in penalties, TD Bank continued operating as a major US bank throughout and after the case.
The comparison with BCCI
TD Bank is arguably the single hardest case to explain away: a major bank pleaded guilty - not settled, pleaded guilty — to a criminal conspiracy to launder money, over a period of years, with its own staff directly implicated, and it kept its doors open the entire time. If a guilty plea of that magnitude was not grounds for closing a top-ten US bank, the double-standards question writes itself: why was a bank with a much smaller, contained 1990 US prosecution - one Senator Orrin Hatch himself said had found no evidence of systemic laundering - shut down worldwide the following year?
Also read:
- United States of America v. TD Bank, N.A.
- TD Bank Pleads Guilty to Bank Secrecy Act and Money Laundering Conspiracy Violations in $1.8B Resolution
- US Department of Justice, “TD Bank Pleads Guilty to Bank Secrecy Act and Money Laundering Conspiracy Violations”, 10 October 2024.
- US Department of Justice, United States v. TD Bank, N.A. case record. Includes the charges, plea agreement and supporting material concerning the US$18.3 trillion transaction-monitoring deficiency.
- US Department of Justice, “TD Bank Insider Pleads Guilty to Facilitating Money Laundering”, 6 January 2026.
- US Department of Justice, “Two TD Bank Insiders Sentenced to Prison for Facilitating Money Laundering, Fraud”, 15 July 2026.
