TD Bank failed to disclose ‘suspicious’ crypto transactions tied to unnamed customer group 

As part of last week’s FinCEN settlement, TD Bank allegedly failed to report transactions related to crypto to relevant law enforcement agencies

article-image

eskystudio/Shutterstock modified by Blockworks

share

As part of a larger investigation into TD Bank’s transactions and adherence to anti-money laundering laws, a FinCEN investigation found that the traditional finance bank failed to disclose “suspicious activity” regarding crypto.

A consent order alleges that the bank processed transactions for “Customer Group C,” which is an unknown entity, “including the facilitation of over $420 million to a financial institution offering cryptocurrency services in the high-risk jurisdiction of Colombia.”

There was a pattern, FinCEN said, of Customer Group C doing over $100 million in wire transfers a month, “most of which facilitated apparent third-party cryptocurrency trading and involved high-risk industries and jurisdictions, including Colombia, China and countries in the Middle East.”

Read more: House hearing on FinCEN oversight turns into crypto debate 

Customer Group C saw transactions top $1 billion in a period of time from July 2023 to April 2024, the order found. Ninety percent of that came from an unnamed crypto exchange, though this one was UK-based. Sixty percent of the outgoing transactions went to a Colombian financial institution — again unnamed. 

The group was also tied to an “international cryptocurrency exchange platform,” the order states, and received over $650 million from it. However, it’s not clear which platform FinCEN is referring to. 

“TD Bank processed these transactions on behalf of Customer Group C, due in part to a lack of clear controls applicable to customers dealing in cryptocurrency: the limited high level written policies the Bank had in place relating to virtual assets alluded to the requirements for certain additional controls and monitoring,” the order claims.

Read more from our opinion section: Crypto is becoming the same broken system it promised to fix

“However, there is no evidence any enhanced controls were ever applied to Customer Group C’s extensive transactions with virtual asset service providers.”

The bank failed to report the activity until it received “multiple law enforcement inquiries” about the unnamed entity.

Last week, TD Bank pleaded guilty to AML violations, paying a hefty fine of $3 billion in penalties. Of that sum, $1.3 billion went to FinCEN according to the order filed with the government office.


Get the news in your inbox. Explore Blockworks newsletters:

Tags

Decoding crypto and the markets. Daily, with Byron Gilliam.

Upcoming Events

Javits Center North | 445 11th Ave

Tues - Thurs, March 24 - 26, 2026

Blockworks’ Digital Asset Summit (DAS) will feature conversations between the builders, allocators, and legislators who will shape the trajectory of the digital asset ecosystem in the US and abroad.

recent research

Flying_Tulip.png

Research

Flying Tulip's perpetual put option provides real principal protection, but investors must pay a valuation premium today for products that have to be built over the next 24 months. This structure works best as a stablecoin substitute where the put allows continuous monitoring—accept opportunity cost in exchange for asymmetric upside if the team executes on its ambitious cross-collateral architecture.

article-image

As flows consolidate and volatility fades, finding edge now means knowing which games are still worth playing

article-image

Value distribution came to $1.9 billion distributed in Q3, though total revenues have yet to beat 2021 heights

article-image

MegaETH public sale auction ends tomorrow, and the free money machine has attracted people who like free money

article-image

With tBTC under the hood, Acre abstracts bridging and converts non-BTC rewards to bitcoin

article-image

Accountable is also eyeing mid-November for mainnet launch

article-image

“Adjusted for size, I think it may be the most successful ETP launch of all time,” Bitwise CIO Matt Hougan says