Groundbreaking Bank Secrecy Act Resolution Signals Increasing Focus on Banks’ Anti-Money Laundering Compliance | Latham & Watkins LLP

Enforcement agencies are pushing for investments in compliance programs.

On October 10, 2024, the Department of Justice (DOJ) announced settlement agreements with TD Bank NA (TDBNA) and its parent company, TD Bank US Holding Company (TDBUSH, and together with TDBNA, the Bank) in connection with anti-money cases. errors in the money laundering program (AML). TDBNA pleaded one count of conspiracy to (1) fail to maintain an adequate AML program; (2) failure to file accurate currency transaction reports; and (3) laundering monetary instruments, in violation of 18 USC § 371. TDBUSH pleaded two substantive violations: (1) causing TDBNA to fail to maintain an adequate AML program; and (2) causing TDBNA to fail to file accurate currency transaction reports, in violation of 31 USC §§ 5322 and 5324. TD Bank became the largest bank in US history to advocate failed Bank Secrecy programs Act (BSA).

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