TD Bank's $3 Billion AML Resolution and CICC's $300K FINRA Fine: What the Monitoring Missed

Updated October 2026. First published October 2024. The first version dated the TD Bank case to 2023 and tied it to the Rothstein Ponzi scheme. The $3 billion resolution was announced on October 10, 2024, and it concerns TD's anti-money laundering program.

Two anti-money laundering cases came out a week apart in October 2024. On October 10, TD Bank pleaded guilty to Bank Secrecy Act and money laundering conspiracy charges, and four U.S. agencies announced penalties that the Federal Reserve put at about $3.09 billion. On October 17, FINRA accepted a settlement from CICC US Securities, Inc., a 36-person broker-dealer in New York, with a censure and a $300,000 fine.

One penalty is about 10,000 times the other. The failure underneath is similar. In both cases, a large share of what the business actually did never reached the monitoring program.

TD Bank: 92% of Volume Went Unmonitored

TD Bank, N.A. pleaded guilty to conspiring to fail to maintain an AML program that met the Bank Secrecy Act, to fail to file accurate currency transaction reports, and to launder money. Its parent, TD Bank US Holding Company, pleaded guilty to causing the program and reporting failures. According to the Justice Department:

• From January 1, 2018 to April 12, 2024, 92% of the bank's total transaction volume, about $18.3 trillion, went unmonitored. The gaps included domestic ACH transfers and most check activity.
• Senior executives enforced a budget mandate known inside the bank as a "flat cost paradigm."
• Three money laundering networks moved more than $670 million through TD accounts. One moved more than $470 million through large cash deposits into nominee accounts, and its operators gave bank employees gift cards worth more than $57,000. Five TD employees conspired with another network, which moved about $39 million to Colombia through ATM withdrawals, and issued it dozens of ATM cards.
• The criminal fine was $1,434,513,478.40 and the forfeiture $452,432,302, after a 20% reduction for partial cooperation and remediation.

FinCEN found that TD didn't file suspicious activity reports on thousands of transactions totaling about $1.5 billion. From 2017 to 2021, the bank handled more than $400 million in transactions for Da Ying Sze, who often brought bags of cash into branches and pleaded guilty to money laundering in 2022. TD failed to identify him in more than 500 currency transaction reports. FinCEN also found that TD's handling of Zelle and Venmo payments missed transactions that pointed to human trafficking, so they weren't reported to FinCEN in time.

The Justice Department credited $123.5 million of its forfeiture toward the Federal Reserve penalty, which is one reason the agency amounts add up to more than the $3.09 billion total.

CICC US Securities: Foreign Trades Outside the Surveillance

CICC US helps U.S. and foreign institutional clients trade in foreign markets, and FINRA describes it as a chaperone between those clients and foreign broker-dealers. It earns commissions on agency trades for 79 institutional customers, many of whom trade heavily in non-U.S. securities through it and its foreign affiliates, and it keeps omnibus account relationships with affiliates abroad. FINRA's AWC No. 2020065116601 covers February 2019 to February 2020. CICC neither admitted nor denied the findings.

• The firm reviewed none of its customers' trades on non-U.S. exchanges for suspicious activity and had no procedures for doing so. It couldn't see signs that a client dominated or manipulated a market.
• Its wash-trade monitoring for low-priced securities looked only at domestic trades and ignored the same customers' foreign trades. Its volume thresholds made patterns hard to spot, and the alerts it did generate weren't reviewed on time.
• In its stock buyback business, it relied on its executing broker's algorithm to keep purchases under the volume limits, including the 25% cap on four-week average daily trading volume. It never checked the algorithm. The broker's calculation errors produced four purchases over the limit, and CICC missed them.
• In September 2019, a corporate customer and an individual tied to it bought back the company's shares through an omnibus account at CICC's foreign affiliate, two days before an announcement that raised the share price. CICC knew about the timing and didn't investigate.

Two findings fall outside AML. CICC's order management system marked every order "unsolicited" by default. No one used the override and no procedure said when to, so all of the more than 22,000 trades in the period went onto the blotter and confirmations as unsolicited, even though analysts at its foreign affiliates gave roadshows and presentations to its investors. And three people who weren't registered were signatories on firm bank accounts that held most of its net capital assets. FINRA Rule 1220 requires anyone with authority to commit a member's capital to be registered as an Operations Professional.

CICC suspended low-priced securities trading and the buyback program in January 2021, hired a compliance consultant in March 2021, and rolled out new procedures and surveillance through 2021.

What Both Programs Missed

TD's gaps were whole payment types. CICC's were whole markets. A business line was running, and the monitoring didn't follow it. These checks come straight from the two orders:

• List every place customer money or securities move: products, payment rails, trading venues, and affiliate omnibus accounts. Mark which ones feed surveillance. Each blank on that list needs a written reason or a fix.
• Test any calculation you rely on from a counterparty or vendor. CICC trusted its executing broker's volume math for a year and never checked it.
• Review every system default that writes into your books and records. CICC's order system tagged 22,000 trades the same way because no one changed one setting.
• Measure how long alerts wait for review. FINRA counted CICC's late reviews against the program.
• Check whether AML staffing and budget moved when volume and risk moved. The Justice Department cited TD's flat budget mandate by name.

FINRA treats red flags as a supervision matter as well as an AML one. The CICC order cites Rule 3110's duty to investigate red flags and act on the results, next to Rule 3310.

This post is for informational purposes only and does not constitute legal advice. For guidance on specific regulatory obligations, consult your counsel or compliance advisor.