Compliance
Bank Of America Penalized For More Than $1.21 Billion In AML, Sanction Violations

Part of the case concerned apparent breaches of sanctions programs covering Iran, Russia, narcotics and global terrorism.
The US Department of the Treasury has imposed penalties totaling
more than $1.21 billion on Bank of America
for violations of anti-money laundering and sanctions
laws.
The Treasury said the actions include the largest penalty in the
history of the Office of the Comptroller of the Currency and the
third largest in its own history.
(Separately, as reported here, Bank of America has reported its third-quarter 2026 results. The bank briefly referred to a "regulatory settlement charge" today. Family Wealth Report has contacted the Charlotte, North Carolina-headquartered bank for comment and may update this article in due course.)
“Financial crime compliance is serious, and we are responsible for getting it right. We worked with regulators to reach these penalty resolutions stemming from violations cited in the previously reported 2024 OCC Consent Order and FinCEN’s investigation. We have invested billions of dollars in technology and dedicated thousands of employees to combat financial crime, and our team is far along with and committed to completing the work required to address the issues raised by our regulators," a BoA spokesperson said.
"We will continue to support federal and local law enforcement across thousands of investigations and report hundreds of thousands of suspicious activity reports each year. Our third-quarter results will include a non-tax-deductible charge of $1.2 billion impacting net income by approximately 17 cents per share. We have already dedicated substantial personnel and resources to our ongoing remediation efforts, and those costs are in the current expense base," the bank.
The Financial Crimes Enforcement Network assessed a $1.2 billion
penalty. The OCC levied a $750 million civil money penalty for a
deficient and ineffective BSA/AML compliance program. The Office
of Foreign Assets Control reached an $11.6 million settlement
over apparent breaches of sanctions programs covering Iran,
Russia, narcotics and global terrorism.
In its resolution with FinCEN, Bank of America admitted
that it wilfully violated the Bank Secrecy Act. It failed to
maintain an adequate AML program, conduct due diligence on
correspondent accounts for foreign financial institutions and
file suspicious activity reports. FinCEN said the bank failed to
report more than $5 billion in suspicious transactions on
time, the US Treasury said in a statement
yesterday.
More than $1 billion of that activity involved priority risks,
including Chinese money laundering networks, fraud and potential
trade-based money laundering tied to the southwest border.
FinCEN said the bank prioritized revenues and limited compliance
resources. It relied on law enforcement inquiries and referrals
from other institutions rather than its own monitoring, in effect
outsourcing much of its detection obligations to third parties.
The bank also failed to act on test results that exposed
weaknesses, and on red flags escalated by its own compliance
staff.
The OCC said the bank’s monitoring system failed to properly
screen trillions of dollars in transactions. Its BSA officer and
staff lacked sufficient expertise. The bank has been subject to
an OCC cease-and-desist order since December 2024, and the
regulator said significant breakdowns continued more than a year
after that order. The 2024 order carried no monetary penalty, but
Bank of America said in its latest quarterly filing that it was
continuing to discuss a resolution with the OCC.
The OFAC settlement covers 475 apparent violations. OFAC judged
them non-egregious and largely not voluntarily self-disclosed and
gave no credit for remediation or cooperation.
Under the FinCEN consent order, the bank must hire a third party
to conduct a lookback and report undetected suspicious
transactions. It must also commission independent reviews of its
monitoring, due diligence and data governance, focused on the
southwest border and cartels, Iran and Russia. The Treasury did
not say which business lines were involved.
“When a bank of this size fails to meet its anti-money laundering
and sanctions obligations, the consequences extend far beyond its
own walls,” Scott Bessent, Treasury Secretary, said.
The action follows the 2024 case against TD Bank, the first bank
in US history to plead guilty to Bank Secrecy Act program
failures. The OCC imposed a $450 million civil penalty on TD Bank
in that case.