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 the criminal resolution, the US Department of Justice described TD Bank N.A. as the 10th-largest bank in the United States.
Background
TD Bank provides one of the most significant recent comparisons with BCCI because the institution did not merely receive a regulatory fine.
On 10 October 2024, TD Bank N.A. pleaded guilty to criminal offences involving conspiracy to:
- fail to maintain an anti-money-laundering programme compliant with the Bank Secrecy Act;
- fail to file accurate Currency Transaction Reports; and
- launder monetary instruments.
Its US holding company simultaneously pleaded guilty to related charges.
Scale and Duration
The deficiencies extended over almost a decade.
Between 2014 and 2023, TD Bank failed adequately to update its AML compliance programme despite known risks. From 2014 through 2022, no new scenarios were added to its transaction-monitoring programme despite recognised deficiencies, emerging risks and the introduction of new products and services.
Between January 2018 and April 2024, approximately 92% of TD Bank’s total transaction volume went unmonitored by its automated transaction-monitoring system, representing approximately US$18.3 trillion in transaction activity.
The Department of Justice stated that TD Bank’s failures enabled three money-laundering networks to transfer more than US$670 million through TD accounts between 2019 and 2023. One of those networks was assisted by five TD Bank employees.
Guilty Plea and Penalties
As part of the criminal resolution, TD Bank agreed to:
- forfeit approximately US$452.4 million;
- pay a criminal fine of approximately US$1.434 billion;
- pay combined DOJ criminal financial penalties of about US$1.8 billion;
- retain an independent compliance monitor; and
- substantially strengthen and remediate its AML programme.
The Department of Justice described the case as involving the largest penalty it had imposed under the Bank Secrecy Act and the first time a US national bank had pleaded guilty to conspiracy to launder money.
Including parallel regulatory settlements, the overall financial consequences were approximately US$3 billion.
Individual Accountability
The enforcement action did not end with the institution.
In January 2026, former TD Bank employee Wilfredo Aquino pleaded guilty to conspiring to launder monetary instruments after facilitating a network that moved hundreds of millions of dollars through TD Bank accounts.
In July 2026, Aquino was sentenced to 46 months in prison. Court records stated that the network moved approximately US$474 million through TD Bank accounts and that Aquino personally processed around 1,680 official bank cheques worth more than US$92 million.
This illustrates an important distinction between:
- prosecuting individual wrongdoing,
- penalising the institution, and preserving legitimate banking operations.
- Institutional Outcome
Despite the criminal guilty plea, prolonged AML failures, involvement of bank employees and exceptionally large financial penalties, TD Bank continued operating.
The response was severe punishment, restrictions, compliance remediation, monitoring and individual prosecution—not closure of the banking franchise.
Comparison with BCCI
The comparison with BCCI is significant.
BCCI was subsequently portrayed in terms suggesting an institution-wide “criminal culture”.
TD Bank, by contrast, provides a modern case in which a major bank itself pleaded guilty to conspiracy involving money laundering, acknowledged extensive AML failures extending over many years, had employees implicated in laundering networks and incurred penalties amounting to billions of dollars.
Yet the regulatory and prosecutorial response distinguished between criminal conduct, institutional responsibility and the continuation of legitimate banking business.
The institution was punished and required to reform, while viable banking operations were preserved.
The Double-Standards Question
If a major North American bank could plead guilty to conspiracy to launder money, acknowledge AML failures extending over many years, have employees implicated in laundering networks and incur approximately US$3 billion in penalties without being closed, why did money-laundering allegations against BCCI contribute to the closure of the institution as a whole?
And:
Does the TD Bank case demonstrate that even serious criminal conduct within a major bank can be prosecuted, penalised and remediated while preserving its legitimate banking operations-and, if so, why was comparable consideration not given to separating wrongdoing within BCCI from the much larger body of legitimate banking activity conducted throughout the Group?
Also read:
- 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.
