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 matters: Documented 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.