Holding Company’s Governance of Anti-Money Laundering (AML) Compliance; An Effective or Ineffective Model – The TD Bank Case Study

The TD Bank case illustrates several vulnerabilities inherent in having AML compliance oversight situated within a parent or holding company. One of the main concerns is the dissonance between those at the top, such as TDBUSH executives with oversight responsibilities, and those executing the program at the subsidiary level, like TDBNA. This distance can result in a lack of operational understanding and a disconnect in the prioritization of compliance risks.

Consider this and other issues deduced from the TD Bank Case in Holding Company’s Governance of Anti-Money Laundering (AML) Compliance; An Effective or Ineffective Model – The TD Bank Case Study