Key Issues and Impacts from Notable Enforcement Actions by U.S. Regulators in 2024

Abstract

This article explores three notable U.S. enforcement actions of 2024 and the key issues and impacts those enforcement actions impart, as we look to 2025 and beyond. In October 2024, TD Bank received a total penalty of over $3 billion, consisting of a $1.3 billion penalty for violations of Bank Secrecy Act (“BSA”) violations from the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”), a $1.8 billion penalty from the U.S. Justice Department (“USDOJ”), $450 million in penalties from the Office of the Comptroller of the Currency (“OCC”), and $123.5 million in penalties from the Federal Reserve Board (“FRB”). There are lessons learned from these different enforcements – shedding light into what mattered most at each agency and what financial institutions can do to prevent being in the same position as TD.