FinCEN has levied a record penalty of $1.3bn against TD Bank, while the U.S. DoJ has imposed an additional $1.8bn in fines for violations of the Bank Secrecy Act (BSA)

According to the settlements, TD Bank failed to implement and maintain an adequate AML program. The bank’s insufficient processing of Venmo and Zelle transactions, which are indicative of human trafficking, resulted in the bank not identifying and reporting these transactions timely to the government.  They also allowed enormous backlogs of potentially suspicious activity to persist, and not adequately report the suspicious activity…