The Council on Ethics recommends that Toronto-Dominion Bank (TD) be placed under observation due to an unacceptable risk that the company is contributing to, or is itself responsible for, serious financial crime, pursuant to section 4(g) of the Guidelines for Observation and Exclusion of Companies from the Government Pension Fund Global.
TD is one of the largest banks in Canada. It also has a significant presence along the USA’s eastern seaboard. The company has more than 95,000 employees worldwide.
The Council’s investigations have found that TD may be linked to multiple cases of financial crime the past 10–15 years.
In 2024, the authorities in the USA and Canada fined TD record sums in relation to money laundering and non-compliance with regulatory requirements intended to combat money laundering. TD was also fined in 2013 in relation to non-compliance with anti-money laundering legislation in the USA. This should have given the company a powerful incentive to improve its routines and internal control procedures. Despite this, the US authorities point out in connection with the fine issued in 2024 that extensive and similar failings in TD’s compliance have existed since 2014.
TD has made sweeping changes to its management in recent times and has adopted an ambitious plan for improvements. These steps, along with the fines imposed, reduce the risk of similar incidents reoccurring. Nevertheless, the Council considers that the extent to which these plans will be realised within the indicated time period remains uncertain, especially in light of the significant amount of work that remains to be done to create a good compliance culture within the company.
The Council on Ethics issued its recommendation on 5 March 2025. Norges Bank published its decision to place TD under observation for a period of four years on 11 June 2025.
Please find the Council’s recommendation here.