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Daily Compliance News

Daily Compliance News: February 17, 2025, The Cancel The Leases Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Retaliation? Musk and DOGE want to cancel federal judiciary leases. (Reuters)
  • DOJ guts bringing of corruption cases. (CNN)
  • Barclay faces a money-laundering investigation. (WSJ)
  • Is settling litigation paying a bribe? (WSJ)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out the FCPA Survival Guide on Amazon.com.

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Daily Compliance News

Daily Compliance News: January 24, 2025, The DEI Goes to War Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Top stories include:

  • Buc-ee’s as a small-town growth machine. (Bloomberg)
  • Great risk for Germany to invest in China. (FT)
  • Vietnam dismantles the AML ring. (Aljazeera)
  • Administration ramps up attacks on DEI. (NYT)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 42 – The Holiday Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode! Today, Tom and Kristy look back at some of their favorite stories from 2024.

 

Stories this week include:

  • Boeing DPA and Monitor
  • Deere FCPA Enforcement Action
  • TD Bank AML enforcement action
  • McKinsey-Opioid and FCPA resolutions
  • Elon Musk’s pay package and corporate governance
  • Musings from the bottom of the world
  • DOJ has received 200 tips since launching the whistleblower program (LEGALDIVE)
  • Sam Bankman-Fried and FTX
  • NYC Mayor Eric Adams, his corruption charges, and a possible Trump Pardon
  • The Greatness of Florida Man

Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

Prove Your Worth

Tom

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending November 30, 2024

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • Larry Thompson looks back. (Press Release)
  • VW to exit Jingjing region of China. (NYT)
  • Hong Kong becoming financial crime hub.  (WSJ)
  • China Defense Minister under investigation for corruption. (FT)
  • Thale under corruption investigation. (BBC)
  • Was it fraud or worse? (NYT)
  • What happens when a company loses its groove.  (WSJ)
  • How the Adani case will test the long arm of US jurisdiction. (Bloomberg)
  • SEC racks up $8bn in penalties under Gensler. (WSJ)
  • 30 Chinese companies added to blacklist.  (WSJ)

For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here.

You can check out the Daily Compliance News for four curated compliance and ethics related stories each day, here.

Check out the full 3-book series, The Compliance Kids on Amazon.com.

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Daily Compliance News

Daily Compliance News: November 11, 2024 – The Veteran’s Day Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

  • NetEase executives arrested for bribery and money laundering.  (gamesindustry.biz)
  • Hidden cost of textile and apparel non-compliance. (Homeland Security Today)
  • Handling a difficult employee with health issues. (NYT)
  • Telefónica Venezuela settles FCPA action. (WSJ)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out the full 3-book series, The Compliance Kids, on Amazon.com.

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Daily Compliance News

Daily Compliance News: November 4, 2024 – The Shame of it All Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four business world stories: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

  • Warren rebukes DOJ over TD Bank settlement.   (WSJ)
  • The Bank of Israel uses shaming to fight money laundering. (TheJerusalemPost)
  • BDO is in hot water for failure to pay an arbitration award for wrongful termination. (FT)
  • Fat Leonard is to be sentenced. (SanDiegoPost)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out the full 3-book series, The Compliance Kids, on Amazon.com.

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10 For 10

10 For 10: Top Compliance Stories For The Week Ending October 26, 2024

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of from the prior week.

Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • Former A&F CEO arrested for sex trafficking. (WSJ)
  • Peru’s ex-President gets 20 years for corruption. (NPR)
  • Charges dropped against Tigran Gambaryan in Nigeria.  (Wired)
  • The Quid Pro Quo-Judge Aileen Cannon on Trump’s short list to be AG. (ABC)
  • FinCEN fines CA Casino over AML violations.  (WSJ)
  • Harris looking at crypto friendly types to head SEC. (Unchained)
  • EY fires staff who took multiple online training courses at the same time.  (FT)
  • Preventing bad behavior at work. (FT)
  • Extreme forum shopping. (CoinDesk)
  • An analysis of Supreme Court’s legalization of corruption.     (NYT)

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Compliance Tip of the Day

Compliance Tip of the Day: TD Bank Lessons Learned – What Does AML/BSA Enforcement Have to Do With ABC?

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Why does every type of compliance professional need to study the TD Bank enforcement Action?

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Blog

TD Bank: Part 5 – The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated separate monitors under their attendant settlement agreements. FinCEN’s Order imposes a four-year independent monitorship, and the DOJ Plea Agreement a 3-year Monitorship. As Matt Kelly noted in Radical Compliance, the remediation steps include:

  • Establishing a dedicated compliance committee at the board level;
  • Drafting a plan within 120 days to overhaul its AML compliance program;
  • Hiring an independent compliance consultant within 60 days to conduct their review of TD’s compliance program;
  • Hiring a senior-level AML compliance officer;
  • Staffing up a more robust AML compliance function; and
  • Implementing new policies, procedures, training, and all the other usual requirements we’ve seen from similar banking settlements.

In this blog post, we will consider some of the highlights above and beyond these remediation steps that the Bank must perform.

The Action Plan

The enforcement order mandates that within 120 days, TDBNA must submit a comprehensive BSA/AML Action Plan to the Examiner-in-Charge for approval. This plan must address the bank’s deficiencies in adhering to the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations. The action plan must include detailed corrective actions, reasonable timelines for implementation, and clear accountability for executing these measures. The board of directors is responsible for overseeing the implementation, ensuring adherence, and monitoring progress, with formal reviews required at least annually.

The Action Plan must be subject to continuous updates and modifications as necessary, particularly if directed by the Examiner-in-Charge or if the bank identifies further areas of improvement. The Examiner-in-Charge must approve any significant deviations or material changes to the plan. TDBNA must also submit quarterly progress reports detailing corrective actions, outstanding issues, and timelines for resolving compliance deficiencies, ensuring transparency in the bank’s efforts to remediate its AML program.

In the event of ongoing issues or independent assessments highlighting further weaknesses, the bank must provide written documentation to the Examiner-in-Charge. The board’s review and response to these assessments will drive accountability and ensure the continuous improvement of TDBNA’s BSA/AML compliance program.

AML Program Assessment and Remediation

TDBNA’s response to its enforcement action underlines the critical role of independent third-party assessments in fortifying a bank’s BSA/AML program. The bank must engage an independent consultant, approved by the OCC, to conduct an exhaustive end-to-end review of its entire BSA/AML framework. This process begins within 60 days of the enforcement order, where TDBNA must submit the proposed consultant’s qualifications, along with a detailed scope of work and timeline, for the OCC’s review. The consultant’s expertise in BSA/AML compliance is a key requirement to ensure the assessment is thorough and capable of addressing the bank’s regulatory obligations.

The independent consultant’s primary objective is to assess the bank’s BSA/AML program against its risk profile, identifying any gaps or weaknesses in its structure and operations. This review will examine whether the bank’s transaction monitoring, suspicious activity reporting, and overall governance are robust enough to meet the demands of U.S. regulatory requirements and the bank’s evolving risk landscape. The consultant’s findings will be critical in determining how effectively TDBNA’s AML framework functions and where improvements are necessary.

Upon completing the review, the consultant will deliver a comprehensive report to TDBNA’s board of directors detailing any deficiencies in the bank’s BSA/AML program. The report will also include recommendations for remediation, ensuring the bank addresses areas of concern in a structured and strategic manner. To ensure transparency and accountability, the board will document its review of the report in official meeting minutes, which must be submitted to the OCC. Additionally, the independent consultant will provide a copy of the report directly to the Examiner-in-Charge, ensuring that regulators have a clear view of the findings and the bank’s planned corrective actions.

Beyond simply identifying deficiencies, the bank must ensure it takes prompt and effective action to remediate the issues raised by the independent consultant. TDBNA must incorporate the necessary remediation efforts into its existing BSA/AML Action Plan, ensuring that all gaps are addressed promptly and comprehensively. This integration is crucial, as failure to properly implement corrective measures could lead to further regulatory actions and potentially severe penalties. The OCC will continue to monitor the bank’s progress by submitting updated action plans and progress reports.

Ultimately, this process highlights the importance of maintaining a dynamic and adaptable BSA/AML program that can respond to emerging risks and regulatory expectations. TDBNA’s engagement with an independent consultant reminds all financial institutions that complacency in AML compliance is not an option. By continually assessing and improving their compliance frameworks, banks can better mitigate risk, avoid regulatory scrutiny, and ensure their AML programs remain strong, effective, and compliant with the law.

Three is Not Always a Crowd

Are you beginning to see a pattern here? The Bank engaged third-party consultants who identified significant weaknesses in its AML program and reported these issues to the Bank’s AML leadership. In 2018, one consultant noted that increasing regulatory requirements and transaction volumes would pressure AML operations, making it difficult to meet demands and deadlines. Additionally, the consultant found that The Bank’s testing of its transaction monitoring scenarios took less than the industry average, highlighting inefficiencies in its ability to assess and capture suspicious activity.

In 2019, another consultant flagged sub-optimal transaction monitoring scenarios based on outdated parameters. These outdated scenarios generated many alerts, overwhelming the AML team and limiting their ability to focus on truly high-risk customers and transactions. This finding pointed to a broader issue in the bank’s ability to adapt its monitoring systems to changing regulatory and risk environments, significantly undermining the effectiveness of its AML compliance efforts.

In 2021, a third consultant identified additional limitations within the Bank’s transaction monitoring program, particularly its technology infrastructure. The consultant found that the bank faced technological barriers that restricted its ability to develop new scenarios or adjust existing parameters, further hampering its AML efforts. These ongoing challenges reflect a broader need for the Bank to modernize its systems and ensure its AML program is agile enough to meet regulatory expectations and address emerging risks effectively.

Restriction on Growth

The Consent Order also required the Bank to maintain its total consolidated assets at or below the level reported on September 30, 2024. This mandate prevents the banks from increasing their average total consolidated assets beyond this threshold until they achieve compliance with all actionable articles of the order. The total consolidated assets will be measured using the banks’ respective Consolidated Reports of Condition and Income.

The asset restrictions will remain in place until the banks meet all compliance obligations outlined in the order. However, the Deputy Comptroller can temporarily suspend the asset cap in unusual circumstances. If the banks fail to meet compliance deadlines, the Deputy Comptroller may require a reduction of up to 7% of their total consolidated assets, as reported in the most recent calendar quarter.

If the Bank is notified that a reduction is necessary, it must submit a plan within 30 days for the Comptroller’s approval and have 60 days to implement the asset reduction. If non-compliance continues beyond the first year, the Deputy Comptroller may impose an additional reduction of up to 7% annually, with the same plan submission and implementation requirements applying each successive year until full compliance is achieved.

Jon Hill wrote in Law360 that this is only the second time “that a federal banking agency has slapped such handcuffs on a financial institution’s overall growth.” The first was Wells Fargo, slapped for its fraudulent accounts scandal. Moreover, while the Wells Fargo “cap has remained in place much longer than many observers originally expected, the OCC has designed its cap for TD Bank with more of a need for remedial speed in mind. In particular, the OCC order establishing the cap includes express provisions that allow the agency to reduce the size limit — that is, tighten the cuffs — by up to 7% annually if the bank does not meet certain deadlines for strengthening its U.S. anti-money laundering compliance.” The article quoted Julie A. Hill, a banking law professor and dean at the University of Wyoming College of Law, for the following, “where the asset cap has gone on for years and years as the bank has tried to get compliant.”

Put Money Where Their Mouth Is

Even more than the commitment to do business ethically and in compliance with its AML/BSA requirements, the Bank must also financially commit to compliance. The Order requires that before the Bank can declare or pay dividends, engage in share repurchases, or make any other capital distributions, the Board of Directors must certify in writing to the Examiner-in-Charge that adequate resources and staffing have been allocated to the remediation efforts required by the OCC’s order. This certification must be submitted at least 30 days before any proposed capital action. It must include a detailed description of the Bank’s current allocation of compliance resources, its progress in remediation, any anticipated changes in resource allocation, and the funding source for the proposed payment or distribution. The goal is to ensure that remediation efforts take priority over capital distributions.

Join us next time, where I will consider TD Bank and the Caremark Doctrine.

Resources

OCC

OCC Press Release

Consent Order 

Civil Money Penalty 

DOJ

TD Bank US Holding Company Information

TD Bank N.A. Information

TD Bank US Holding Company Plea Agreement and Attachments

TD Bank N.A. Plea Agreement and Attachments

Merrick Garland Remarks

Nicole Argentieri Remarks

FinCEN

Press Release

Consent Order

Categories
Blog

TD Bank: Part 4 – Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to long-term Congressional hearings, at least when they were not the claptrap theater we have in place today. Perhaps the single thing I remember the most clearly was Tennessee Senator Howard Baker’s question, “What did the President know, and when did he know it?” The answer that we learned during the Watergate hearings was that President Nixon had known all along that the crimes of Watergate originated in the White House. Today, I want to use that question to explore what TD Bank knew, when they knew, and what that tells us about the culture of the world’s 30th-largest bank and 10th-largest bank in the US.

Prior OCC, FinCEN, and DOJ Enforcement Actions

In September 2013, the OCC and FinCEN levied a $37.5 million civil monetary penalty against the Bank for violating the Bank Secrecy Act (BSA) related to a Ponzi scheme run by a Florida attorney. Despite the numerous AML alerts triggered by its transaction monitoring system, the Bank failed to identify and report approximately $900 million in suspicious activity. This failure stemmed, in part, from inadequate anti-money laundering (AML) training for both AML and retail personnel. FinCEN emphasized that poorly resourced and trained staff managing critical compliance functions is unacceptable, underscoring the importance of adequate training and resources in compliance programs.

Following these enforcement actions, the Bank needed to adapt its transaction monitoring system to address its deficiencies substantively. The OCC had directed the bank to establish policies and procedures that could respond systematically and promptly to environmental or market changes, such as developing new monitoring scenarios. However, the bank’s failure to implement these recommendations meant it could not effectively mitigate emerging risks. This oversight revealed significant gaps in the Bank’s AML compliance efforts, particularly its ability to adjust its program to evolving threats.

In 2015, the OCC instructed the Bank to enhance its transaction monitoring program for high-risk customers, who were subject to the exact scenarios and thresholds as the rest of the Bank’s customers despite their higher risk profile. In 2016,  the AML function and the Bank technology teams began to develop new high-risk customer scenarios. That effort was put on hold in October 2016 by AML executives due to a lack of resources. After being briefly revived in early 2017, this project was again put on hold, this time by the head of AML at the Bank partly due to “cost.” Although US-AML leadership informed the OCC during its 2017, 2018, and 2019 examinations that these scenarios were in development, the Bank never implemented the required enhanced transaction monitoring of high-risk customers. By 2018, the OCC determined that the Bank’s planning and execution of its AML technology systems remained insufficient. The Bank had delayed implementing key AML technology projects, which directly contributed to its failures around AML compliance.

The Bank even misrepresented itself to the Department of Justice (DOJ). In February 2018, the Bank entered a settlement over its failure to file Suspicious Activity Reports (SARs). The Bank’s issues were partly due to its cessation of transaction monitoring scenario threshold testing. The Bank’s US-AML executives were aware of this resolution and acknowledged the importance of monitoring transactions for suspicious activity. One key AML leader at THE BANK emphasized that their AML team reviewed similar enforcement actions to ensure their compliance programs aligned with regulatory expectations, particularly around scenario threshold testing.

He explained to the AML Oversight Committee that the Bank conducted a detailed analysis below scenario thresholds to determine if SARs should have been filed, adjusting thresholds accordingly. This approach was intended to avoid the failures that led to the other bank’s settlement. However, despite these assurances, by early 2018, THE BANK’s AML team and its technology partners effectively halted its threshold testing due to competing priorities and resource limitations.

As a result, between 2018 and 2022, the Bank conducted threshold testing, or “quantitative tuning,” on only one out of approximately 40 U.S. transaction monitoring scenarios. This significant reduction in testing left gaps in the Bank’s AML compliance program, potentially exposing the bank to similar risks and regulatory scrutiny that had affected other institutions in the industry.

Where Was Internal Audit?

The question in these massive enforcement actions is often, ‘Where was the internal audit?’ Regarding the Bank, the answer is simple: Right Here, Doing Our Job. In 2018, the Bank’s Internal Audit function uncovered a critical issue within the bank’s AML program: the high-risk jurisdiction transaction monitoring scenarios were based on an outdated list, meaning the bank was not flagging transactions from jurisdictions currently deemed high-risk. This oversight severely impacted the bank’s ability to monitor and address risks associated with these regions. The findings revealed a gap in how the bank’s transaction monitoring system adapted to evolving regulatory expectations and global risk landscapes, compromising the effectiveness of its AML efforts.

By 2020, Internal Audit highlighted even more deficiencies in the bank’s AML compliance, specifically related to the governance and review of transaction monitoring scenarios. Among the key issues were a need for formal timelines for completing scenario reviews, some of which had been outstanding since 2017, and the failure to implement proposed changes from the previous year. Moreover, there needed to be a formal process or documentation to guide the promotion of new monitoring scenarios, a governance gap mirroring issues identified by the OCC seven years earlier. These systemic failures indicated a troubling lack of progress in strengthening the bank’s AML compliance framework.

Despite the findings from 2018 and 2020, Internal Audits reviewed in the following years revealed that these issues remained unresolved. The Bank’s Board of Directors was informed of these ongoing deficiencies and remediation plans, yet the persistent gaps in governance and scenario management continued to hinder the bank’s ability to respond to AML risks effectively. For those keeping score at home, that means Actual Knowledge at the Board.

Three Clarion Calls

Are you beginning to see a pattern here? The Bank engaged third-party consultants who identified significant weaknesses in its AML program and reported these issues to the Bank’s AML leadership. In 2018, one consultant noted that increasing regulatory requirements and transaction volumes would pressure AML operations, making it difficult to meet demands and deadlines. Additionally, the consultant found that The Bank’s testing of its transaction monitoring scenarios took less than the industry average, highlighting inefficiencies in its ability to assess and capture suspicious activity.

In 2019, another consultant flagged sub-optimal transaction monitoring scenarios based on outdated parameters. These outdated scenarios generated many alerts, overwhelming the AML team and limiting their ability to focus on truly high-risk customers and transactions. This finding pointed to a broader issue in the bank’s ability to adapt its monitoring systems to changing regulatory and risk environments, significantly undermining the effectiveness of its AML compliance efforts.

In 2021, a third consultant identified additional limitations within the Bank’s transaction monitoring program, particularly its technology infrastructure. The consultant found that the bank faced technological barriers that restricted its ability to develop new scenarios or adjust existing parameters, further hampering its AML efforts. These ongoing challenges reflect a broader need for the Bank to modernize its systems and ensure its AML program is agile enough to meet regulatory expectations and address emerging risks effectively.

The AML Leadership Team

During the relevant period, the Bank’s AML leadership consisted of key individuals whose responsibilities significantly shaped the Bank’s approach to AML compliance, and, more importantly, all knew of the Bank’s AML deficiencies. They were identified as Individual-1, Individual-2, and Individual-3 in the Information. Individual-1 was hired in 2013 as VP of AML Operations and rose to become the sole Chief AML Officer by 2019, overseeing the bank’s global AML program. His role included setting the annual AML budget, developing strategic priorities, and regularly reporting to the board of directors. Individual-1’s oversight extended to AML technology services and the U.S. Financial Intelligence Unit (FIU), reflecting his pivotal role in the U.S. and global AML operations.

Individual 2 joined THE BANK in 2014 as Head of the U.S. FIU and was critical in overseeing the investigative teams responsible for reporting suspicious activities and managing high-risk customers. By 2019, Individual-2 had assumed the role of BSA Officer and Deputy Global Head of AML Compliance, where they were responsible for managing the U.S. AML program. However, despite these responsibilities, Individual 2 faced limitations due to the Chief AML Officer’s direct control over AML technology, a crucial aspect of the bank’s AML operations, which created challenges in overseeing technology-related AML issues.

Individual-3, a vice president within AML Operations, took on significant responsibilities within the U.S. FIU, especially between 2017 and 2018. In this role, Individual-3 managed the initial review of transaction monitoring alerts and the handling of Unusual Transaction Referrals (UTRs) and reports of suspicious activity submitted by employees. Together, these key figures shaped THE BANK’s AML efforts, though the division of responsibilities and challenges with AML technology governance highlighted areas of vulnerability within the bank’s compliance framework.

What did the Bank know, and when did they know it? As the Information rather dryly noted, “US-AML, including senior leadership, were aware of the lack of domestic ACH and check monitoring.” More importantly, like President Nixon, they knew about their AML failures and consciously chose not to do anything about them.

Resources

Join us tomorrow when I will consider the reckoning for the Bank.

Resources

 OCC

OCC Press Release

Consent Order 

Civil Money Penalty 

DOJ

TD Bank US Holding Company Information

TD Bank N.A. Information

TD Bank US Holding Company Plea Agreement and Attachments

TD Bank N.A. Plea Agreement and Attachments

Merrick Garland Remarks

Nicole Argentieri Remarks