Consent Order Imposing Civil Money Penalty on TD Bank, N.A. and TD Bank USA, N.A.

UNITED STATES OF AMERICA
FINANCIAL CRIMES ENFORCEMENT NETWORK
DEPARTMENT OF THE TREASURY
IN THE MATTER OF: )
) Number 2024-02
TD Bank, N.A. and TD Bank USA, N.A. )
)
CONSENT ORDER IMPOSING CIVIL MONEY PENALTY
The Financial Crimes Enforcement Network (FinCEN) conducted a civil enforcement investigation and determined grounds exist to impose a Civil Money Penalty against TD Bank, N.A. and TD Bank USA, N.A. (collectively, TD Bank or the Bank)1 for violations of the Bank Secrecy Act (BSA) and its implementing regulations.2 TD Bank admits only to the facts admitted in the October 10, 2024 plea agreements between T.D. Bank, N.A. and TD Bank US Holding Company and the U.S. Department of Justice (DOJ) and neither admits nor denies the remainder of the facts set forth herein, consents to the issuance of this Consent Order, agrees to pay the civil money penalty imposed in this Consent Order, and agrees to comply with the provisions of this Consent Order, including, but not limited to, the Undertakings. 1 References to TD Bank or the Bank herein refer collectively to TD Bank, N.A. and TD Bank USA, N.A., not to the TD Bank Group or The Toronto-Dominion Bank. For part of the Relevant Time Period, the Bank’s BSA Officer reported to TD Bank US Holding Company’s board of directors as well as the audit committee thereof (as well as the Global Head of AML). References to the board of directors are to TD Bank’s board (the Bank’s Board) or its parent TD Bank US Holding Company’s board (U.S. Parent Board), unless expressly stated otherwise (collectively, the Boards). Similarly, references to executives are to employees of TD Bank unless stated otherwise. 2 The BSA is codified at 12 U.S.C. §§ 1829b, 1951-1960, 31 U.S.C. §§ 5311-5314, 5316-5336 and includes other authorities reflected in notes thereto. Regulations implementing the BSA appear at 31 C.F.R. Chapter X.