Last week, U.S. Attorney General Merrick B. Garland announced in Washington that TD Bank, one of the nation's largest Financial Institutions Groups, had pleaded guilty to multiple felony charges, including conspiracy to violate the Bank Secrecy Act and money laundering. In a statement, Mr. Garland confirmed that TD agreed to accept a $1.80 billion criminal penalty, which, when combined with civil enforcement actions, would total about $3 billion. He noted that the resolution included "the largest penalty ever under the Bank Secrecy Act and the first time the Department of Justice has conducted a daily fine assessment of a bank."