What the TD Bank and Bank of America Cases Reveal About Cross-Border Financial Crime
Commentary Financial crime rarely respects international borders, although responsibility for detecting it remains largely national. Transactions may pass through banks and companies in several countries before investigators identify their origin or destination. Recent U.S. enforcement actions involving Bank of America and TD Bank offer a useful comparison, particularly for Canada, where financial crime can affect economic security.

TL;DR
- Financial crime often transcends national borders, while detection remains primarily a national responsibility.
- Bank of America was penalized over US$1.21 billion by the U.S. Treasury for anti-money-laundering and sanctions violations.
- Regulators cited over US$5 billion in suspicious activity that was not reported in a timely manner.
- Weaknesses were identified in detecting transactions linked to Chinese money-laundering networks and illicit finance along the U.S.-Mexico border.
- Separate sanctions matters involved programs related to Russia and Iran.
- The enforcement actions offer a comparison for Canada, where financial crime can impact economic security.