Audit log

Every state-changing event for TD Bank: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1publishby system:backfill

   2026-05-14 06:02:15Z
   Score: ? → ? (no score change)
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   {"actor":"system:backfill","investigation_id":"4d3a1bc6-8e6e-4b8d-9510-2690a4e0aff2","kind":"publish","page_slug":"td-bank","published_at":"2026-05-14T06:02:15.263Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"TD Bank","sections":[{"content":"<cite index=\"1-1,2-2\">In October 2024, TD Bank pleaded guilty to conspiracy to commit money laundering, becoming the largest bank in U.S. history to do so, and agreed to pay over $3 billion in penalties to resolve investigations into money laundering and Bank Secrecy Act violations.</cite> <cite index=\"2-6,3-10\">The Justice Department found that TD Bank allowed at least three different money laundering networks to move a total of $670 million through TD Bank accounts over several years, while failing to monitor a stunning $18.3 trillion in customer activity.</cite> <cite index=\"2-9,2-11\">In one notable case, an individual known as \"David\" moved more than $470 million in drug proceeds through TD Bank branches, bribing employees with over $57,000 in gift cards, and was able to deposit more than $1 million in cash in a single day due to the bank's \"most permissive policies.\"</cite> <cite index=\"2-16,8-21\">High-level executives were aware of serious problems but failed to correct them, with employees openly joking about the situation, including using the bank's motto \"America's most convenient bank\" as a joke about being convenient for criminals.</cite>","heading":"Money Laundering Scandal and Criminal Guilty Plea","severity":"critical","sources":[{"credibility":1,"name":"NPR - TD Bank $3 billion settlement announcement","type":"news_article","url":"https://www.npr.org/2024/10/11/g-s1-27671/td-bank-justice-department"},{"credibility":1,"name":"CNBC - TD Bank guilty plea and penalties","type":"news_article","url":"https://www.cnbc.com/2024/10/10/td-bank-3-billion-fine-doj-settle-money-laundering-drug-cartel.html"},{"credibility":1,"name":"U.S. Department of Justice - Criminal case documentation","type":"official","url":"https://www.justice.gov/criminal/case/united-states-america-v-td-bank-na"}]},{"content":"<cite index=\"11-1,11-3\">The Office of the Comptroller of the Currency imposed a $434 billion asset cap on TD's U.S. retail banking operations, limiting the bank's total consolidated assets to those reported as of September 30, 2024.</cite> <cite index=\"12-6,12-7\">If the bank fails to achieve compliance by the OCC-approved timeline, regulators may require TD to reduce its total consolidated assets by up to 7%, with potential additional 7% reductions for each successive year of noncompliance.</cite> <cite index=\"12-8,19-1\">The bank cannot open new branches or enter new markets without receiving no supervisory objection from regulators.</cite> <cite index=\"11-9,13-14\">The restriction is similar to the asset cap imposed on Wells Fargo in 2018, which remains in place after more than six years and has been described as \"very difficult to get out of regulatory jail when you have this kind of pervasive oversight failure.\"</cite> <cite index=\"19-12,19-13\">To stay below the asset cap, TD has announced plans to intentionally shrink and make targeted retreats from certain businesses, including auto dealer financing and correspondent mortgage operations.</cite>","heading":"Asset Cap and Business Restrictions","severity":"high","sources":[{"credibility":2,"name":"Banking Dive - TD asset cap and penalties","type":"news_article","url":"https://www.bankingdive.com/news/td-asset-cap-3b-penalty-aml-woes-doj-occ-fed-fincen/729506/"},{"credibility":1,"name":"OCC Fact Sheet - Cease and Desist Order","type":"regulatory","url":"https://www.occ.gov/news-issuances/news-releases/2024/nr-occ-2024-116a.pdf"},{"credibility":2,"name":"American Banker - Asset cap analysis","type":"news_article","url":"https://www.americanbanker.com/news/td-to-exit-certain-u-s-businesses-after-being-hit-with-asset-cap"}]},{"content":"<cite index=\"1-2,4-6\">TD Bank failed to substantively update its transaction monitoring program between 2014 and 2022, resulting in 92% of transaction volume and 74% of transaction value going unmonitored, corresponding to over $18.3 trillion in unmonitored transactions.</cite> <cite index=\"1-12,4-12\">The bank operated under a \"flat-cost year-over-year spending paradigm\" where senior leadership imposed budget constraints mandating that the AML budget not increase despite the bank's profits and risk levels surging.</cite> <cite index=\"4-15,4-16\">The case involved defendant Da Ying Sze, known as \"David,\" who conspired to launder over $653 million, with more than $470 million laundered through TD Bank, and even bribed bank employees with over $57,000 in gift cards.</cite> <cite index=\"8-17,8-18\">Federal regulators began penalizing the bank for lack of money laundering controls as early as 2013, but the bank continued to prioritize growth over compliance despite repeated warnings.</cite>","heading":"Systemic Anti-Money Laundering Failures","severity":"critical","sources":[{"credibility":2,"name":"Financial Services Perspectives - TD Bank settlement analysis","type":"research","url":"https://www.financialservicesperspectives.com/2024/10/td-banks-historic-3-1b-money-laundering-settlement-a-warning-to-all-financial-institutions/"},{"credibility":2,"name":"International Compliance Organization - TD Bank case study","type":"research","url":"https://www.int-comp.org/insight/the-high-price-of-negligence-inside-td-banks-record-fine/"},{"credibility":2,"name":"New Jersey Monitor - Federal penalties report","type":"news_article","url":"https://newjerseymonitor.com/2024/10/10/feds-hit-td-bank-with-3b-in-penalties-for-money-laundering-scheme-benefitting-drug-traffickers/"}]},{"content":"<cite index=\"21-2,21-4\">TD Bank Group traces its roots to 1855 with the founding of The Bank of Toronto by local millers and merchants, and The Dominion Bank chartered in 1869, which merged in 1955 to form The Toronto-Dominion Bank.</cite> <cite index=\"26-15,26-17\">TD ranks as Canada's second largest bank in terms of assets and serves about ten million customers through TD Canada Trust's retail operations with approximately 1,000 branches and over 2,700 ATMs.</cite> <cite index=\"23-17,23-20\">Today TD serves over 27 million customers across North America with about 2,200+ retail locations and fiscal 2024 assets near C$1.9 trillion, having entered the U.S. by acquiring Banknorth in 2004-2007 and Commerce Bancorp in 2008.</cite> <cite index=\"25-1,25-4\">The bank operates through a diversified business model with multiple segments including retail banking, wholesale banking services, and wealth management, generating revenue through extensive retail banking operations and broad financial product offerings.</cite>","heading":"Bank Background and Business Model","severity":"low","sources":[{"credibility":3,"name":"MatrixBCG - TD Bank history overview","type":"research","url":"https://matrixbcg.com/blogs/brief-history/td"},{"credibility":2,"name":"Reference for Business - TD company profile","type":"research","url":"https://www.referenceforbusiness.com/history2/49/The-Toronto-Dominion-Bank.html"},{"credibility":2,"name":"TD Official History - Corporate website","type":"official","url":"https://www.td.com/ca/en/about-td/corporate-profile/tds-history"}]}],"sources_used":[{"credibility":1,"name":"U.S. Department of Justice - Criminal Division case","type":"official","url":"https://www.justice.gov/criminal/case/united-states-america-v-td-bank-na"},{"credibility":1,"name":"NPR - TD Bank settlement report","type":"news_article","url":"https://www.npr.org/2024/10/11/g-s1-27671/td-bank-justice-department"},{"credibility":1,"name":"CNBC - TD Bank penalties coverage","type":"news_article","url":"https://www.cnbc.com/2024/10/10/td-bank-3-billion-fine-doj-settle-money-laundering-drug-cartel.html"},{"credibility":1,"name":"Office of the Comptroller of the Currency - Enforcement action","type":"regulatory","url":"https://www.occ.gov/news-issuances/news-releases/2024/nr-occ-2024-116.html"},{"credibility":2,"name":"Banking Dive - Asset cap analysis","type":"news_article","url":"https://www.bankingdive.com/news/td-asset-cap-3b-penalty-aml-woes-doj-occ-fed-fincen/729506/"}],"summary":"TD Bank is a major North American financial institution formed in 1955 from the merger of two Canadian banks. In October 2024, the bank faced historic penalties totaling over $3 billion after pleading guilty to money laundering conspiracy charges, resulting in severe business restrictions and regulatory oversight.","timeline":[{"date":"1855-03-18","event":"The Bank of Toronto incorporated by grain merchants and millers","source":"TD Official History","source_url":"https://www.td.com/ca/en/about-td/corporate-profile/tds-history"},{"date":"1869-05-24","event":"The Dominion Bank chartered in Toronto","source":"TD Official History","source_url":"https://www.td.com/ca/en/about-td/corporate-profile/tds-history"},{"date":"1955-02-01","event":"Bank of Toronto and Dominion Bank merge to form Toronto-Dominion Bank","source":"TD Official History","source_url":"https://www.td.com/ca/en/about-td/corporate-profile/tds-history"},{"date":"2008-01-01","event":"TD acquires Commerce Bancorp, forming TD Bank \"America's Most Convenient Bank\"","source":"TD Official History","source_url":"https://www.td.com/ca/en/about-td/corporate-profile/tds-history"},{"date":"2013-01-01","event":"Federal regulators begin penalizing TD Bank for lack of AML controls","source":"New Jersey Monitor","source_url":"https://newjerseymonitor.com/2024/10/10/feds-hit-td-bank-with-3b-in-penalties-for-money-laundering-scheme-benefitting-drug-traffickers/"},{"date":"2014-01-01","event":"Beginning of period where TD failed to update transaction monitoring systems","source":"DOJ Criminal Division","source_url":"https://www.justice.gov/criminal/case/united-states-america-v-td-bank-na"},{"date":"2024-10-10","event":"TD Bank pleads guilty to money laundering conspiracy, agrees to $3+ billion in penalties","source":"NPR","source_url":"https://www.npr.org/2024/10/11/g-s1-27671/td-bank-justice-department"},{"date":"2024-10-10","event":"OCC imposes $434 billion asset cap on TD's U.S. operations","source":"Banking Dive","source_url":"https://www.bankingdive.com/news/td-asset-cap-3b-penalty-aml-woes-doj-occ-fed-fincen/729506/"}]},"v":1}

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2. #2reviewby reviewerreviewer

   2026-06-14 23:15:57Z
   Score: 30 → 30 (no score change)
   Blue-chip calibration review (Prompt A). Verdict: over-penalized. Page content is treated as accurate; the trust_score band is miscalibrated. TD Bank is a fully legitimate, publicly traded major North American financial institution — not a scam, Ponzi scheme, or exit fraud. The October 2024 guilty plea to money laundering conspiracy and the $3.09B+ in penalties represent genuine, severe, confirmed institutional negligence: the bank intentionally under-resourced its AML compliance program under a 'flat cost paradigm' for nearly a decade, enabling criminal networks to launder over $600M through unmonitored accounts. This is own-negligence attribution, not third-party abuse of an innocent victim. Under AVOID.NET's current band semantics, WARNING (20-49) is reserved for 'elevated fraud/loss risk or unresolved severe incident'; CAUTIONARY (50-69) covers 'legitimate with material caveats.' The incident was historic and severe, but the bank is actively remediating (spending $500M+/yr, majority of AML work complete per American Banker), under independent monitorship (Guidepost Solutions), already in compliance with the OCC asset cap, and remains one of North America's largest regulated financial institutions. A score of 52 in CAUTIONARY reflects the seriousness of the proven institutional failure and unresolved monitorship obligations, while correctly distinguishing a negligent-but-legitimate institution from a fraudulent one. An outside skeptic can verify: the DOJ case page, FinCEN press release, OCC consent order, and American Banker's 2025 remediation report all support this calibration.
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   canonical bytes (1952 B) ▸

   {"actor":"reviewer","decided_at":"2026-06-14T23:15:57.459Z","decision":"review","investigation_id":"4d3a1bc6-8e6e-4b8d-9510-2690a4e0aff2","new_score":30,"page_slug":"td-bank","prev_score":30,"reason":"Blue-chip calibration review (Prompt A). Verdict: over-penalized. Page content is treated as accurate; the trust_score band is miscalibrated. TD Bank is a fully legitimate, publicly traded major North American financial institution — not a scam, Ponzi scheme, or exit fraud. The October 2024 guilty plea to money laundering conspiracy and the $3.09B+ in penalties represent genuine, severe, confirmed institutional negligence: the bank intentionally under-resourced its AML compliance program under a 'flat cost paradigm' for nearly a decade, enabling criminal networks to launder over $600M through unmonitored accounts. This is own-negligence attribution, not third-party abuse of an innocent victim. Under AVOID.NET's current band semantics, WARNING (20-49) is reserved for 'elevated fraud/loss risk or unresolved severe incident'; CAUTIONARY (50-69) covers 'legitimate with material caveats.' The incident was historic and severe, but the bank is actively remediating (spending $500M+/yr, majority of AML work complete per American Banker), under independent monitorship (Guidepost Solutions), already in compliance with the OCC asset cap, and remains one of North America's largest regulated financial institutions. A score of 52 in CAUTIONARY reflects the seriousness of the proven institutional failure and unresolved monitorship obligations, while correctly distinguishing a negligent-but-legitimate institution from a fraudulent one. An outside skeptic can verify: the DOJ case page, FinCEN press release, OCC consent order, and American Banker's 2025 remediation report all support this calibration.","score_delta":0,"sequence_num":2,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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3. #3review approveby judgejudge

   2026-06-14 23:15:57Z
   Score: 30 → 52 (+22)
   This blue-chip calibration review found 0% disputed claims — all six claim_findings[0–5] are marked supported. The page content accurately documents TD Bank's October 2024 guilty plea, $3.09B+ in penalties, and a decade of intentional AML under-investment. The miscalibration is in the trust_score band, not the facts: a score of 30 (WARNING) is reserved for elevated fraud or unresolved severe incidents, but TD Bank is a fully regulated, publicly traded major institution actively remediating under an independent compliance monitor. claim_findings[3] specifically confirms the bank has spent $507M on AML overhaul, completed the majority of remediation, and is already below the OCC asset cap — mitigating factors not reflected at 30. A score of 52 (CAUTIONARY) correctly acknowledges the severity of proven institutional negligence while distinguishing a negligent-but-legitimate institution from a fraudulent one. The review was conducted at high confidence (0.88) with strong exonerating evidence that the current band is demonstrably too harsh, warranting a positive score_modifier_delta of +22.
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   {"actor":"judge","decided_at":"2026-06-14T23:15:57.459Z","decision":"review_approve","investigation_id":"4d3a1bc6-8e6e-4b8d-9510-2690a4e0aff2","new_score":52,"page_slug":"td-bank","prev_score":30,"reason":"This blue-chip calibration review found 0% disputed claims — all six claim_findings[0–5] are marked supported. The page content accurately documents TD Bank's October 2024 guilty plea, $3.09B+ in penalties, and a decade of intentional AML under-investment. The miscalibration is in the trust_score band, not the facts: a score of 30 (WARNING) is reserved for elevated fraud or unresolved severe incidents, but TD Bank is a fully regulated, publicly traded major institution actively remediating under an independent compliance monitor. claim_findings[3] specifically confirms the bank has spent $507M on AML overhaul, completed the majority of remediation, and is already below the OCC asset cap — mitigating factors not reflected at 30. A score of 52 (CAUTIONARY) correctly acknowledges the severity of proven institutional negligence while distinguishing a negligent-but-legitimate institution from a fraudulent one. The review was conducted at high confidence (0.88) with strong exonerating evidence that the current band is demonstrably too harsh, warranting a positive score_modifier_delta of +22.","score_delta":22,"sequence_num":3,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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