In October 2024, Toronto Dominion Bank (TD Bank) became the first bank in U.S. history to plead guilty to conspiracy to commit money laundering. Canada’s second largest bank, and tenth largest in the United States, allowed money-laundering networks to deposit money at its branches, and facilitate the transfer of money to criminal organizations, including drug cartels located in South America. The conspiracies began in 2014. Investigations by the U.S. Department of Justice reveal that illegal drug money was laundered through TD Bank branches in three states. As a result, drug traffickers were able to expand their operations according to Department of Justice officials.¹

“Our anti-money-laundering laws dictate that a bank that willfully fails to protect against criminal schemes is also a criminal. That is what TD Bank was” said U.S. Attorney General Merrick Garland at a news conference where he announced TD Bank’s guilty plea.² Mr. Garland mentioned that TD Bank’s procedures and systems for monitoring transactions were deficient, and that the bank failed to monitor more than US$18 trillion in customer activity over a six-year span that started in 2018.³ During the past decade, criminal networks found that TD Bank had “the most permissive policies and procedures, and chose to launder money there” Mr. Garland added.⁴ Red flags and warnings from TD employees were ignored by managers and executives on numerous occasions.⁵

Consequences for TD Bank

The consequences for TD Bank are severe. It must pay fines totaling US$3.09 billion, and meet several restrictions imposed by U.S. regulators.⁶ These restrictions include an indefinite cap on asset growth in the United States, restrictions on opening new branches, restrictions on launching new products, restrictions on paying dividends, and an independent assessment of the bank’s anti-money-laundering (AML) program in the United States.⁷ TD Bank must also relocate its AML and compliance programs to the United States (to be overseen by U.S. regulators as opposed to Canadian regulators). In addition, the bank must submit to an independent review of its board of directors, and submit to an independent review that will assess employee involvement in facilitating money laundering, and failures to flag issues of money laundering.⁸ Finally, the bank is disqualified from serving as investment advisor or underwriter to investment companies registered in the United States, and from providing asset management services to certain employee benefit plans.⁹

The indefinite cap on TD Bank asset growth in the United States is considered the most severe penalty. The bank is on probation to improve its AML and compliance programs. Regulators can force the bank to shrink its U.S. assets by as much as 7 percent each year that improvements are deemed unsatisfactory.¹⁰ The cap is particularly troublesome for the bank, since thirty percent of its growth comes from the United States.¹¹ TD Bank was planning to open 150 new retail branches in the United States by 2027.¹² Instead of planning an expansion, the bank is now shrinking its U.S. mortgage, auto loan and investment management portfolios to avoid going over the cap. The bank also decided to sell 40 million shares of its investment in a leading U.S. discount-brokerage firm.

Following the guilty plea, two credit rating agencies lowered TD Bank’s debt ratings on “concerns over governance weaknesses and anti-money-laundering failures that led U.S. regulators and prosecutors to impose tight restrictions on the lender’s growth in the American market”¹³ and “over concerns that the findings regarding TD’s U.S. management hamper our view of its conservative risk management and effective corporate governance”¹⁴ (Moodys, S&P Global). Lenders and investors refer to credit ratings when assessing the risk of providing financing to a company by way of loans and bond purchases. A lower rating translates into a higher cost of borrowing.

The reputation of TD Bank is severely tarnished, which negatively impacts it share valuations. “Management’s credibility and reputation have been harmed, in our view, and will likely be reflected in a discounted valuation versus its peers for years to come” said Darko Mihelic, analyst at RBC Dominion Securities, in a note to investors.¹⁵ The investment firm downgraded its target for TD Bank shares by seven percent following the guilty plea. TD Bank now trades at a twelve percent discount (on average) to large Canadian banks. Its share price has fallen by a third since early 2022, resulting in a loss of market value totaling US$45 billion during a three year period. By comparison, the market value of its main rival (Royal Bank of Canada) rose fifteen percent during the same period, resulting in a market value increase of US$25 billion. TD Bank was trailing Royal Bank in market value by US$8 billion early in 2022. The gap is now ten times larger at US$80 billion.

As a result of its tarnished reputation, TD Bank experienced several employee departures within its most senior ranks, including the recent departure of its chief executive officer. Analysts report that “a number of senior TD leaders have left the bank, which is battling perceptions that its highly regarded culture, which made the bank stand out, has eroded.”¹⁶ Notable departures include the chief operating officer, the group head of Canadian banking, an executive vice-president of finance, an executive of non-financial risk management, and a mortgage business leader.¹⁷ Many other leaders and managers were asked to leave or terminated as a result of the money-laundering scandal. TD Bank will likely have much difficulty attracting and retaining talent in its senior ranks.

Consequences for TD Employees

It is reported that several former TD employees have been charged with accepting bribes and conspiring to commit or facilitate money laundering. These former employees could face up to 20 years in prison.¹⁸ Criminal investigations are ongoing, and the U.S. Department of Justice has said that “no one involved in TD Bank’s illegal conduct will be off limits.”¹⁹ Employee morale is deeply affected throughout the organization. Employees “expressed embarrassment, sadness and anger over all that went wrong for a decade” as part of meetings and town halls.”²⁰ TD executives in Canada said their teams were in a “state of shock” when details of the guilty plea were made public. Employees question how compliance systems missed money-laundering transactions for years. Some employees struggle to reconcile constant reminders about compliance, while so many managers and executives were complacent about money-laundering issues for years.²¹

Consequences for Canadian Regulators

The consequences for Canadian regulators are very embarrassing and troubling. The astonishing case against TD Bank and its admission of guilt demonstrate how Canadian federal government departments and agencies are inept at supervising financial institutions, and ensuring compliance. These departments and agencies include the Canadian Department of Finance, the Canadian Office of the Superintendent of Financial Institutions (OSFI), and the Canadian Financial Transactions and Reports Analysis Centre (FinTRAC).²² As a result of TD Bank failings, Canadian regulators are going to be evaluated by the Financial Action Task Force (FATF) said Alana Scotchmer, a partner at the international law firm Gowling WLG.²³ The FTAF is an intergovernmental organization whose main objective is to tackle money laundering, terrorist and proliferation financing. It is scheduled to conduct its evaluation during 2025-2026. The FATF previously reported in 2016 that “Canada requires improvement in some areas, including a lack of coverage in some areas.”²⁴

As part of its plea agreement, TD Bank must relocate to the United States the portions of its anti-money-laundering program that are responsible for ensuring U.S. compliance. It is no longer an option for TD Bank to manage its U.S. compliance from Canada. “This program will be subject to oversight by U.S. regulators” said the Federal Reserve Board in a press conference following the plea agreement. Regulators in the United States are questioning how their Canadian counterparts failed to discover and remedy problems with TD Bank’s anti-money-laundering risks and controls. Observers perceive this development as a “black eye” for Canadian regulators.²⁵ It speaks volumes about the loss of confidence in Canada’s regulatory regime according to observers.²⁶

Main Causes of the Failures

1)  Problem Culture

TD Bank has a long history of failures associated with money laundering and other types of financial crimes. Early in the 2010’s “regulators identified numerous deficiencies with TD’s AML program.”²⁷ The bank completed most of its remedial actions by 2013, and regulators “concluded that executives were committed to resolving the rest.”²⁸ A new compliance management software was implemented in 2016. However, the implementation was a disaster because the new software did not properly integrate with other software systems. TD Bank “struggled to consolidate data across the enterprise to monitor and identify risks such as recognizing patterns at specific branches or from repeat customers.”²⁹ As problems dragged on, new managers of the AML compliance program did not maintain their commitment to fix the integration issues. There were concerns that the program was getting treated as a cost center as opposed to an essential service, according to people familiar with the situation.³⁰ In 2013, the bank was fined US$52.5 million for its role in a Ponzi scheme. In 2023, TD Bank “agreed to pay US$1.2 billion to settle a lawsuit over another scheme. The bank was accused of missing or ignoring red flags in both of these cases.³¹

As part of its plea agreement, TD Bank admitted to “starving its compliance program of the resources needed to obey the law.” The result was that “TD Bank’s transaction monitoring program remained effectively static, and did not adapt to address known, glaring deficiencies; emerging money laundering risks; or TD’s new products or services” said officials of the U.S. Department of Justice.³² Department officials also reported that “TD’s failure to prevent money laundering was known by a wide range of employees, including two senior managers responsible for overseeing the anti-money-laundering program.” Officials also said that over more than a decade, regulators, internal auditors and external consultants repeatedly warned TD Bank executives and the board about issues with the bank’s transaction-monitoring program.³³

Merrick Garland, Attorney General of the United States (head of the U.S. Department of Justice) said in a news conference following the guilty plea that “TD Bank chose profits over compliance, in order to keep its costs down. That decision is now costing the bank billions of dollars in criminal and civil penalties.”³⁴ Lisa Monaco, Deputy Attorney General, added that “every bank compliance official should be reviewing [the indictment and guilty plea] as a case study of what not to do.”³⁵ Michael J. Hsu, Acting Comptroller of the U.S. Office of Currency further stated that “the bank’s blatant risk management failures attracted illicit actors, and are egregious and unacceptable.”³⁶

TD Bank failures to prevent money laundering were known by many of its employees, including senior managers responsible for overseeing its anti-money-laundering compliance program. According to the investigation, regulators, internal auditors and external consultants “repeatedly warned executives and the board about issues with the bank’s transaction-monitoring program.”³⁷ The failures were “egregious, pervasive and well known even at senior levels of the bank, marking TD as a place where low-level employees joked openly about the bank being an easy target for bad actors, while senior executives failed to act on warnings”³⁸ said Department of Justice officials. Employee e-mails read by Mr. Garland at the news conference, provided clear evidence of such behaviors.³⁹ “TD Bank created an environment that allowed financial crime to flourish. By making its services convenient for criminals, it became one” said Mr. Garland.⁴⁰

2)  Weak Governance

In its plea agreement, TD Bank admitted to allowing criminals to launder hundreds of millions of dollars.⁴¹ The bank’s senior executive leaders and boards of directors in the United States and Canada were specifically informed by internal auditors in 2018 and 2020 of compliance program deficiencies and failures, and the lack of a plan to fix all of the issues.⁴² TD Bank had “staggering and pervasive failures in oversight” said the Department of Justice, and “willfully failed to monitor trillions of dollars of transactions” at retail branches located in the United States.⁴³ “We expect boards to comprehensively examine their oversight of risks and synthesize them into an enterprise-wide approach to protect their institutions from threats to their integrity and security” said Peter Routledge, Superintendent of Financial Institutions in Canada.⁴⁴

As part of remediation requirements, the U.S. Federal Reserve Board requires TD Bank to conduct an independent review of its boards of directors and management. Critics have called on TD Bank “to reassess the makeup of its board of directors, citing a lack of financial crime and compliance expertise among its directors.”⁴⁵ Elizabeth Warren, U.S. Senator and former law professor, warned that senior executives must be held accountable. “Until and unless those executives who presided over TD Bank’s institutionalized money laundering are held accountable, banks will continue to factor enforcement fines into the cost of doing business, rather than approaching compliance with our money laundering laws with the seriousness it requires” said Senator Warren.⁴⁶

TD Bank had “staggering and pervasive failures in oversight” emphasized the Department of Justice.⁴⁷ Over the 10 year period cited by Department officials, TD Bank’s audit committee was “largely populated by directors who did not work for long periods in the banking industry. For most, their biographies suggest little experience with anti-money-laundering controls. Until recently, the majority of members of the TD audit committee were not professional accountants.”⁴⁸ By the end of 2023, it was reported that five of six audit committee members were professional accountants.⁴⁹ This sharp contrast of audit committee membership attests to the fact that professional accountants are among the best qualified for financial and risk management oversight.

3)  Ineffective Canadian Regulators

Canada’s regulatory oversight for money laundering has been ineffective for years. In 2008, the Financial Action Task Force (FATF) raised concerns about Canada’s Office of the Superintendent of Financial Institutions (OSFI) in meeting global anti-money-laundering standards. FATF concluded that “sanctions remain infrequently used, and do not appear to be sufficiently effective, proportionate and dissuasive.”⁵⁰ In 2020, the National Post reported that Canada was ranked lowest among developed nations for cracking down on money laundering.⁵¹ Not surprisingly, the U.S. Bureau for International Narcotics and Law Enforcement Affairs labels Canada as one of the world’s “major money laundering countries.”⁵² In its 2023 report, the Bureau describes that “money laundering in Canada involves the proceeds of illegal drug trafficking, fraud, corruption, counterfeiting and piracy, and tobacco smuggling and trafficking, among others. (…) Transnational organized crime groups and professional money launderers are key threat actors.”⁵³

A public inquiry completed by the province of British Columbia during 2022 “delivered a sweeping rebuke of Ottawa’s anti-money-laundering regime, finding billions of dollars of criminal funds flowing annually through casinos, real estate and luxury goods in the absence of effective federal law enforcement.”⁵⁴ The final report of the inquiry [known as the Cullen Commission] recommends that the provincial government create its own intelligence and investigation police unit to tackle money laundering because of ineffectiveness at the federal level. Former British Columbia Supreme Court justice Austin Cullen wrote in his report that “law enforcement bodies in British Columbia cannot rely on [Canadian federal government regulators] to produce timely, useful intelligence about money laundering activity that they can put into action. (…) Given the state of the federal regime, if the province is to achieve success in the fight against money laundering, it must develop its own intelligence capacity in order to better identify money-laundering threats” wrote Mr. Cullen. David Eby, Attorney General for British Columbia reacted by saying that “the report, frankly, is an indictment of failures around the federal anti-money-laundering regime.”⁵⁵

In Canada, TD Bank was fined approximately CA$9 million (US$6 million) for the failures of its anti-money-laundering controls. While the amount is ridiculously low for a very large bank, it is surprisingly the largest-ever fine levied by the Financial Transactions and Reports Analysis Centre of Canada (FinTRAC). According to its website, FinTRAC is “Canada’s financial intelligence unit, and anti-money laundering and anti-terrorist financing supervisor. Its mandate is to facilitate the detection, prevention and deterrence of money laundering and the financing of terrorist activities, while ensuring the protection of personal information under its control.”⁵⁶ Jessica Davis, President of advisory firm Insight Threat Intelligence, suggests that the TD Bank case highlights the differences between Canada and the United States when it comes to penalizing companies for failing to comply with anti-money-laundering obligations. “It’s going to be really important for Canada to be more proportional to the United States” said Ms. Davis.⁵⁷ An overly polite understatement to say the least.

U.S. regulators justly question why their Canadian counterparts “failed to spot and remedy problems with TD’s anti-money-laundering risk controls.” Evidently and for several years, Canadian regulators were totally blind to the risks posed by TD Bank’s problem culture and weak governance related to money laundering. The big question is why? How could this possibly happen? The reasons are in fact very simple. The bank “maintained elements of an anti-money-laundering program that looked adequate on paper”⁵⁸ Canadian regulators were naïve and easily fooled. They failed to conduct effective audits to verify and validate the program. In addition, there was confusion between regulatory agencies over their responsibilities for money-laundering oversight.⁵⁹ These situations demonstrate incompetence and negligence at the highest organizational levels.

Actions by TD Bank

To address orders from the U.S. Department of Justice and U.S. regulators, TD Bank says that it is “revamping its risk and compliance team, overhauling its governance structure, updating its policies and processes, and upgrading its technology platforms.”⁶⁰ The changes are sweeping and may take years to implement and satisfy authorities according to observers. “We need to improve and strengthen our enterprise-wide program” said former Chief Executive Bharat Masrani. “We did not meet our expectations or our regulatory obligations to monitor, detect, report and respond to suspicious transactions activity. As a result, criminals broke through our defenses and used the bank to launder money. This is absolutely unacceptable” said Mr. Masrani in a memo to employees.⁶¹

Ray Chun, TD Bank’s new Chief Executive, is conducting a “broad and detailed review of the bank’s strategies and investment priorities to position TD Bank to compete over the medium and longer term [given the cap on U.S. asset growth]. Everything is on the table” said Mr. Chun.⁶² During 2024, TD Bank’s chief compliance officer departed, and the bank recruited “a respected expert on preventing financial crime to advise its chief risk officer Ajai Bambawale.”⁶³ During 2024, TD Bank also replaced its board chairperson, and actively recruited new directors to strengthen oversight. “We have established dedicated committees for regulatory remediation oversight and benchmarked our corporate governance program. In addition, we are reviewing our board committees and anticipate changes in chairs and composition in the new year” said TD Bank’s new board chair Alan MacGibbon.⁶⁴ “We are committed to sound corporate governance and regularly review our practices and policies to align with legal and regulatory expectations and industry best practices” said TD Bank spokesperson Lisa Hodgins in an e-mailed statement.⁶⁵

During 2024, TD Bank hired “several new anti-money-laundering and compliance professionals, and is exploring technology and restructuring the division to enhance its monitoring program” according to TD Bank’s new AML program chief Herbert Mazariegos. “Compliance should not be seen as an expense, but rather as a key investment that saves on costs in the long run” said Mr. Mazariegos.⁶⁶ During 2024, TD Bank also hired global consulting firm McKinsey for advice and support on regulatory matters,⁶⁷ and hired risk management and audit services firm Protiviti for assistance in improving its anti-money-laundering program and controls.⁶⁸

Conclusions

TD Bank shareholders are paying a heavy price for management’s greed, incompetence, negligence, and complacency for the bank’s AML compliance program failures. The incompetence and lack of oversight by TD Bank’s boards of directors are appalling and deplorable. The bank is on probation and time is of the essence. TD Bank must address all regulatory orders at a brisk pace and satisfactorily, or face a mandatory seven percent annual decline of its U.S. assets. TD Bank is very lucky to keep its banking charter in the United States. Regulators could have revoked the charter, but chose instead to give the bank one last change to get its act together. Changes to TD Bank’s board composition, senior executive replacements, and declarations by former and new executives very clearly attest that TD Bank was not previously taking its anti-money-laundering and compliance programs seriously. A drastic culture change is required. Those previously complacent, joking about, or facilitating money-laundering transactions should all be terminated for cause. Money-laundering complicity at a major financial institution is no laughing matter.

A similar message applies to the Canadian Department of Finance and its regulatory agencies, namely OSFI and FinTRAC. The ineffective anti-money laundering oversight at these institutions demonstrates an incredible amount of incompetence and complacency. The ridiculously low fines that they levy on major financial institutions to deter non-compliance demonstrate a complete lack of judgment. Those responsible for ineffective regulatory oversight must be held accountable. It is very embarrassing and concerning that the Canadian federal government and its agencies are no longer trusted when it comes to money-laundering oversight. Fortunately, a change of government is soon expected in Canada, after nine long years of Liberal party incompetence and complacency.

Endnotes

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¹  J Turley-Ewart, Canadian regulators are at fault for TD’s money-laundering troubles, (Globe & Mail, Aug 23, 2024).
²  J Bradshaw and T Kiladze, Lapses were well known at lender’s senior levels, DOJ finds, (Globe & Mail, Oct 11, 2024).
³  J Bradshaw and T Kiladze, Lapses were well known at lender’s senior levels, DOJ finds, (…).
⁴  J Bradshaw and T Kiladze, Lapses were well known at lender’s senior levels, DOJ finds, (…).
⁵  Stefanie Marotta, TD leadership should face charges over U.S. findings, Senator says, (Globe & Mail, Nov 1, 2024).
⁶  Stefanie Marotta, Former TD Bank employee accused of assisting money-laundering ring, (Globe & Mail, Dec 12, 2024).
⁷  Stefanie Marotta, TD guilty of conspiracy to launder money in U.S., (Globe & Mail, Oct 11, 2024).
⁸  Stefanie Marotta, TD guilty of conspiracy to launder money in U.S., (…).
⁹  J Turley- Ewart, TD Bank’s problems are plain for all to see, and it is a worrisome sight (Globe & Mail, Dec 6, 2024).
¹⁰ J Turley- Ewart, TD Bank’s problems are plain for all to see, and it is a worrisome sight (…).
¹¹ Naimul Karim, U.S. money-laundering sanctions put cloud of uncertainty over TD, (Ottawa Citizen, Oct 12, 2024).
¹² Stefanie Marotta, TD guilty of conspiracy to launder money in U.S., (Globe & Mail, Oct 11, 2024).
¹³ Stefanie Marotta, Moody’s downgrades some TD ratings over governance concerns, (Globe & Mail, Oct 25, 2024).
¹⁴ Stefanie Marotta, Moody’s downgrades some TD ratings over governance concerns, (…).
¹⁵ J Bradshaw and A Willis, U.S. restrictions will force TD to change its business strategy (Globe & Mail, Oct 12, 2024).
¹⁶ J Bradshaw, TD posts rare quarterly loss as bank braces for billions in penalties, (Globe & Mail, Aug 23, 2024).
¹⁷ Tim Kiladze, et.al., TD Bank’s dirty laundry, (Globe & Mail, Aug 17, 2024).
¹⁸ Stefanie Marotta, Former TD Bank employee accused of assisting money-laundering ring, (Globe & Mail, Dec 12, 2024).
¹⁹ Naimul Karim, U.S. money-laundering sanctions put cloud of uncertainty over TD, (Ottawa Citizen, Oct 12, 2024).
²⁰ J Bradshaw and A Willis, U.S. restrictions will force TD to change its business strategy (Globe & Mail, Oct 12, 2024).
²¹ J Bradshaw and A Willis, U.S. restrictions will force TD to change its business strategy (…).
²² J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (Globe, Oct 15, 2024).
²³ N Balu, Canada proposes more powers for money-laundering regulator amid increasing scrutiny (Reuters, Dec 17, 2024).
²⁴ N Balu, Canada proposes more powers for money-laundering regulator amid increasing scrutiny (…).
²⁵ Rita Trichur, TD needs to give investors a straight answer about what went wrong in the U.S., (Globe, Oct 12, 2024).
²⁶ Rita Trichur, TD needs to give investors a straight answer about what went wrong in the U.S., (…).
²⁷ Tim Kiladze, et.al., TD Bank’s dirty laundry, (Globe & Mail, Aug 17, 2024).
²⁸ Tim Kiladze, et.al., TD Bank’s dirty laundry, (…).
²⁹ Tim Kiladze, et.al., TD Bank’s dirty laundry, (…).
³⁰ Tim Kiladze, et.al., TD Bank’s dirty laundry, (…).
³¹ Tim Kiladze, et.al., TD Bank’s dirty laundry, (…).
³² J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (Globe, Oct 15, 2024).
³³ Stefanie Marotta, Moody’s downgrades some TD ratings over governance concerns, (Globe & Mail, Oct 25, 2024).
³⁴ Stefanie Marotta, TD guilty of conspiracy to launder money in U.S., (Globe & Mail, Oct 11, 2024).
³⁵ J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (Globe, Oct 15, 2024).
³⁶ Stefanie Marotta, TD guilty of conspiracy to launder money in U.S., (Globe & Mail, Oct 11, 2024).
³⁷ Stefanie Marotta, Moody’s downgrades some TD ratings over governance concerns, (Globe & Mail, Oct 25, 2024).
³⁸ J Bradshaw and T. Kiladze, Lapses were well known at lender’s senior levels, DOJ finds, (Globe & Mail, Oct 11, 2024).
³⁹ Andrew Willis, Internal e-mails reveal a culture that will haunt bank, (Globe & Mail, Oct 11, 2024).
⁴⁰ Andrew Willis, Internal e-mails reveal a culture that will haunt bank, (…).
⁴¹ David Milstead, TD Bank’s highly paid board members failed to fix years of rot, (Globe & Mail, Oct 16, 2024).
⁴² David Milstead, TD Bank’s highly paid board members failed to fix years of rot, (…).
⁴³ David Milstead, TD Bank’s highly paid board members failed to fix years of rot, (…).
⁴⁴ R Trichur and S Marotta, Banking regulator orders TD to overhaul risk controls […], (Globe & Mail, Aug 23, 2024).
⁴⁵ Stefanie Marotta, TD suspends financial targets, launches strategic review after U.S. probe, (Globe & Mail, Dec 6, 2024).
⁴⁶ Stefanie Marotta, TD leadership should face charges over U.S. findings, Senator says, (Globe & Mail, Nov 1, 2024).
⁴⁷ J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (Globe, Oct 15, 2024).
⁴⁸ J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (…).
⁴⁹ J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (…).
⁵⁰ J Turley-Ewart, Canadian regulators are at fault for TD’s money-laundering troubles (Globe and Mail, Aug 23, 2024).
⁵¹ Diane Francis, Canada lags in action on money laundering, (National Post, Dec 6, 2024).
⁵² Bureau for International Narcotics and Law Enforcement Affairs, International Narcotics Control Strategy Report Volume 2: Money Laundering (United States Department of State, March 2023).
⁵³ Bureau for International Narcotics and Law Enforcement Affairs, International Narcotics Control Strategy Report Volume 2: Money Laundering (United States Department of State, March 2023).
⁵⁴ Justine Hunter, Federal anti-money-laundering agency a failure, inquiry finds, (Globe & Mail, Jun 16, 2024).
⁵⁵ Justine Hunter, Federal anti-money-laundering agency a failure, inquiry finds, (…).
⁵⁶ FinTRAC website (https://fintrac-canafe.canada.ca/intro-eng), Accessed January 2025.
⁵⁷ Alexandra Posadzki, Banks face big hike in fines for failures to control financial crime, (Globe & Mail, Dec 18, 2024).
⁵⁸ J Turley- Ewart, U.S. case against TD demolishes Canada’s reputation [for] bank supervision, (Globe, Oct 15, 2024).
⁵⁹ Alexandra Posadzki, Banks face big hike in fines for failures to control financial crime, (Globe & Mail, Dec 18, 2024).
⁶⁰ Stefanie Marotta, TD suspends financial targets, launches strategic review after U.S. probe, (Globe & Mail, Dec 6, 2024).
⁶¹ Stefanie Marotta, TD CEO tells staff he’s ‘deeply disappointed’ by AML failings, (Globe & Mail, May 8, 2024).
⁶² Adriano Marchese, Toronto-Dominion Bank Suspends Growth Targets as It Reviews Business, (WSJ, Dec 5, 2024).
⁶³ J Bradshaw, TD pegs $2.6-billion more for U.S. penalties, (Globe & Mail, Aug 22, 2024).
⁶⁴ Stefanie Marotta, TD suspends financial targets, launches strategic review after U.S. probe, (Globe & Mail, Dec 6, 2024).
⁶⁵ Stefanie Marotta, Shareholder advocacy group calls on TD Bank to review board practices, (Globe & Mail, Nov 23, 2024).
⁶⁶ Stefanie Marotta and Alexandria Posadzki, TD’s new anti-money-laundering chief says financial sector can learn from bank’s shortcomings, (Globe & Mail, Nov 8, 2024).
⁶⁷ Stefanie Marotta, TD earmarks $450-million for penalties in U.S. regulatory investigation, (Globe & Mail, Nov 8, 2024).
⁶⁸ Rita Trichur and Stefanie Marotta, Banking regulator orders TD to overhaul risk controls […], (Globe & Mail, Aug 23, 2024).