The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties.

In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank’s compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank’s strategy is a clear warning when a business puts profits over compliance. 

Key Highlights

·      Introduction to the Flat Cost Paradigm

·      Details of the Budget Strategy

·      Impact on Anti-Money Laundering Efforts

·      Financial Growth Amidst Budget Constraints

Resources

1.    Blogs

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

2.     Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

3.    Enforcement Related Material

A.    OCC

OCC Press Release

Consent Order 

Civil Money Penalty 

B.    DOJ

TD Bank US Holding Company Information

TD Bank N.A. Information

TD Bank US Holding Company Plea Agreement and Attachments

TD Bank N.A. Plea Agreement and Attachments

Merrick Garland Remarks

Nicole Argentieri Remarks

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