TD Bank, N.A. and TD Bank USA, N.A.

TD Bank's AML Program Failures The document reveals severe underinvestment in Anti-Money Laundering (AML) compliance by TD Bank, leading to significant risks and harm to the U.S. financial system. The bank's inadequate AML program resulted in trillions of dollars in unmonitored transactions, including peer-to-peer payments and checks, and failed to timely file suspicious activity reports, hindering financial crime investigations. Key Compliance Considerations The document highlights the importance of effective AML compliance programs, adequate staffing, and sufficient resources. It emphasizes the need for timely reporting of suspicious activity and accurate monitoring of high-risk transactions.