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Managing Risk at TD
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TD’s Risk Appetite
We take risks required to build our business, but only if those risks:
1
Fit our business strategy and can be understood and managed.
2
Do not expose the enterprise to any significant single loss events; TD does not “bet the bank” on any single acquisition, business, product or decision.
3
Do not risk harming the TD brand
TD’s Risk Culture
A strong risk culture is fundamental to TD’s success. It shapes how the Bank seizes opportunities, navigates challenges and maintains its focus on the future. Doing the right thing is at the heart of our risk culture and reflects who we are as a Bank.
The Bank fosters an environment where colleagues feel empowered to take ownership, escalate issues and continuously build their risk knowledge. Every day, TD colleagues across the enterprise do the right thing and Own it, Raise it and Know it.
These behaviours underpin a strong risk culture and are critical to achieving our vision, remaining successful in a complex and competitive operating environment and driving better outcomes for clients, colleagues and communities.
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A Closer Look: Progress on TD’s Anti-Money Laundering (AML) Program
In 2025, TD stayed focused on delivering against its top priority, advancing remediation efforts and strengthening its AML program across the Bank.
Key achievements on the remediation of TD’s U.S. AML program include:
Continued strengthening leadership and talent.
Enhanced client onboarding procedures and strengthened cash deposit requirements.
Improved investigative procedures with updated guidelines and streamlined workflow.
Implemented role-based targeted training and enhanced Bank-wide general training to reinforce understanding and accountability.
Deployed a new transaction monitoring platform with enhanced scenario coverage and capabilities.
Implemented specialized artificial intelligence (AI) and machine learning capabilities.
Continued making progress on lookback reviews.
While the Bank has made progress on this remediation effort, significant work and important milestones remain in this multi-year endeavour to implement a strong, effective and sustainable AML program. TD remains steadfast in its commitment to this critical work.
