In a critical juncture for Canada's second-largest bank, Toronto-Dominion Bank's (TD Bank) chief compliance officer, Monica Kowal, has departed the organization. Kowal's exit comes as the bank works to address deficiencies in its anti-money laundering (AML) program, which has drawn the attention of US regulators and law enforcement.
Steering the Bank Through Regulatory Turbulence
Addressing Compliance Shortcomings
The departure of Kowal, a seasoned compliance professional, coincides with TD Bank's efforts to rectify issues within its regulatory compliance management (RCM) framework. The bank's regulator, the Office of the Superintendent of Financial Institutions (OSFI), had previously identified gaps in TD Bank's RCM program, prompting the institution to undertake a comprehensive remediation initiative.The RCM framework is a critical component for banks, as it enables them to manage the various laws and regulations governing their operations across Canada, the United States, and other jurisdictions. Effective RCM programs are essential for banks to mitigate regulatory compliance risks, including those related to AML.
Prolonged Scrutiny and Potential Penalties
TD Bank has been under prolonged scrutiny by US regulators and the Department of Justice for weaknesses in its AML procedures. Analysts estimate that the potential penalties the bank may face could reach up to billion. Additionally, there are concerns that US regulators might impose restrictions on TD Bank's ability to expand in its key growth market, further complicating the bank's compliance challenges.
Navigating the Compliance Transformation
Kowal, a lawyer and former regulator, had been instrumental in overseeing TD Bank's efforts to address the RCM program's shortcomings. She worked closely with two vice-presidents of compliance, Denise Morris and Emily Jelich, to spearhead the remediation efforts. Jelich has since retired from the bank, further underscoring the significance of Kowal's departure.
Erin Morrow: The New Compliance Leader
To fill the vacancy left by Kowal's departure, TD Bank has appointed Erin Morrow, the deputy chief compliance officer, as her successor. Morrow, who joined the bank in January from Citibank, where she held compliance and auditing roles for over a decade, brings over 20 years of experience in compliance, audit, and risk management.In the internal memo announcing Morrow's appointment, TD Bank's chief risk officer, Ajai Bambawale, praised her impact within the compliance organization and her role in building the compliance transformation team. Morrow's leadership will be crucial in steering the bank through its ongoing compliance challenges and ensuring robust AML controls are in place.
Navigating the Regulatory Landscape
As TD Bank continues to address the regulatory issues it faces, the bank's ability to effectively manage its compliance obligations will be paramount. The departure of Kowal, a seasoned compliance professional, coupled with the ongoing RCM remediation efforts and the heightened scrutiny from US regulators, underscores the complexity of the compliance landscape that the bank must navigate.Morrow's appointment as the new chief compliance officer represents a critical juncture for TD Bank. Her experience and expertise will be instrumental in guiding the bank through its compliance transformation, ensuring that it can effectively address the deficiencies in its AML program and mitigate the potential regulatory penalties and restrictions it faces.The successful navigation of these compliance challenges will not only be crucial for TD Bank's reputation and financial stability but will also have broader implications for the banking industry as a whole. As the regulatory environment continues to evolve, the ability of financial institutions to maintain robust compliance frameworks will be a key differentiator in an increasingly complex and scrutinized landscape.
