A CLOSER LOOK

Progress on Our U.S. Anti-Money Laundering Program

A multi-year effort is underway to implement a strong, effective, and sustainable U.S. Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program. We are committed to this critical work and have mobilized the necessary resources to deliver. Progress to date includes:

  • People & Talent

    • Appointed a new U.S. Head of Financial Crime Risk Management and BSA/AML Officer with deep experience and subject matter expertise.
    • Established a dedicated and expanded U.S. Financial Crime Risk Management leadership team and hired new resources across the first line of defence with experience in critical areas such as risk management and control, and a focus on Financial Crime.

    Governance & Structure

    • Strengthened oversight structure and accountability across all three lines of defence, from the front lines through to risk management and audit.
    • Established dedicated committees at the TDBG Board of Directors and U.S. Boards.

    Policy & Risk Assessment

    • Introduced new standards with the goal of increasing capabilities to measure financial crime risk more effectively.
    • Designed and implemented new risk limits, and introduced changes to certain risk assessment processes.

  • Process & Control

    • Enhanced customer onboarding procedures for cash intensive clients and added additional transactions to the Bank’s monitoring system.
    • Implemented role-based targeted training and revised Bank-wide general training to reinforce understanding and accountability.

    Data & Technology

    • Deployed new data-driven technology solutions and rolled out the first phases of an improved transaction monitoring platform.
    • Increased speed of investigation activities and enhanced proactive modelling of current risks through advanced analytics.

    Enhancing the Bank’s U.S. AML program is a top priority and TD is committed to the work required to meet its regulatory obligations. We have the financial strength, stability, and operational flexibility to both address our AML matters and continue to serve the financial needs of our customers and clients.