TD Bank, N.A. — $115,005.04 OFAC penalty
OFAC published a $115,005.04 civil penalty against TD Bank, N.A. on 12/23/2021. It is the #223 largest action in OFAC’s 1,052-entry enforcement chart and #16 of the 18 actions published that year.
The record
| Entity, as published by OFAC | TD Bank, N.A. |
|---|---|
| Penalty / settlement amount | $115,005.04 |
| Date published by OFAC | 12/23/2021 |
| Aggregate penalties, settlements or findings | 2 |
| Rank among all published OFAC actions | #223 of 1,052 |
| Rank within 2021 | #16 of 18 |
| Share of 2021 penalty total | 0.6% |
| Statutory maximum penalty | $224,470,875 |
| Base penalty | $191,343 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | North Korea |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $224,470,875. The settled amount of $115,005.04 is 0.1% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20211223_TDBNA.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2021 actions
- An Individual — $133,860
- Schlumberger Rod Lift, Inc. — $160,000
- NewTek, Inc. — $189,483
- MoneyGram Payment Systems, Inc. — $34,328.78
- Alfa Laval Inc. — $16,875
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