The discussion highlights the potential for regulatory shifts, particularly around CRA and Dodd-Frank 1071, though changes may take 18-24 months. The conversation shifts to the unprecedented $3 billion penalty against TD Bank.

In a press release from the  Department of Justice, Attorney General Merrick Garland said, "By making its services convenient for criminals, TD Bank became one." 

The press release also said the TD Bank plea marked "the first instance of a U.S. bank pleading guilty to conspiracy to commit money laundering" and describes a situation in which "TD Bank faced systemic compliance failures, including inadequate internal controls, deficient transaction monitoring, and neglect of suspicious activity reporting, leading to extensive violations of BSA/AML regulations".

The podcast underscores the importance of well-resourced and up-to-date compliance programs, as TD Bank's deficiencies highlight the consequences of prioritizing other objectives over regulatory obligations. As stated in the DOJ press release, Deputy Attorney General Lisa Monaco said, "Every bank compliance official in America should be reviewing today's charges as a case study of what not to do. And every bank CEO and board member should be doing the same. Because if the business case for compliance wasn't clear before - it should be now".

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