Law enforcement officials stumbled on TD Bank’s role in money laundering while investigating a Mexican drug cartel. They found that the bank’s corporate culture considered compliance, particularly Bank Secrecy Act and anti-money laundering (BSA/AML) compliance, a low priority. As they dug deeper, authorities discovered that multiple money laundering schemes had infiltrated the bank’s network.

When announcing a blistering series of fines totaling $3 billion against the Toronto-based bank, regulators said the bank’s AML compliance program had failed to grow along with the emerging risks that came with TD Bank’s expanding business. The failure was so widespread that regulators believe the company’s leadership, including its board of directors, had made a purposeful decision to underfund compliance, instead prioritizing growth and higher profits. 

“TD Bank prioritized growth and convenience over following its legal obligations,” said U.S. Attorney Philip Sellinger for the District of New Jersey, in a Department of Justice (DOJ) press release that laid out the agency’s enforcement action against TD Bank.