TD Bank — $3.1B Historic AML Settlement
TD Bank pleaded guilty to conspiracy to commit money laundering — the largest US bank ever to do so. From 2014-2023, executives prioritized the bank's "flat cost paradigm" over an adequate AML program. Transaction monitoring intentionally excluded all domestic ACH and most check activity.
Why it mattersDocumented controls are not effective controls. TD's AML monitoring existed on paper but excluded 92% of transactions by design. The RCSA effectiveness scoring rubric — "does it work," not "do we have it" — and the testing calendar by risk tier are built to surface gaps like this.