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nid 95696
Oct 14, 2026
pdonofrio@vixio.com
US Track 2
U.S. Department of the Treasury
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2327 charsUS Department of the Treasury Announces Record Enforcement Actions Against Bank of America
On October 13, 2026, the U.S. Department of the Treasury announced enforcement actions imposing more than $1.21 billion in penalties against Bank of America for violations of anti-money laundering and sanctions laws. The Financial Crimes Enforcement Network (FinCEN) assessed a $1.2 billion penalty, the third-largest in Treasury history and largest in Office of the Comptroller of the Currency (OCC) history, for the bank's failure to mitigate and report priority national security risks, including Chinese Money Laundering Networks and illicit finance along the southwest border. The OCC assessed a $750 million civil money penalty for deficient and ineffective Bank Secrecy Act and anti-money laundering (BSA/AML) compliance programs. The Office of Foreign Assets Control (OFAC) announced an $11.6 million settlement for apparent violations of sanctions programs targeting Iran, Russia, Belarus, Burma, Somalia, narcotics, and global terrorism.
FinCEN's investigation found that Bank of America willfully violated the BSA by failing to implement adequate AML programs, conduct proper due diligence for correspondent accounts, and file suspicious activity reports (SARs). The bank failed to report over $5 billion in suspicious transactions to FinCEN, with over $1 billion implicating national security risks. Bank of America prioritized revenues over compliance resources and outsourced suspicious activity detection to law enforcement inquiries and other financial institutions rather than relying on internal controls. The OCC penalty addressed the bank's deficient transaction monitoring system, which failed to properly monitor trillions of dollars in transactions, resulting in large numbers of late SARs involving billions of dollars. OFAC's settlement covered 475 apparent violations resulting from technical and human error in sanctions compliance.
As remediation, Bank of America must complete a third-party lookback to identify and report previously undetected suspicious transactions and undergo independent reviews of its suspicious activity monitoring, customer due diligence, and foreign correspondent account due diligence programs. Treasury emphasized that financial institutions cannot disregard mounting red flags or rely on external sources as substitutes for effective internal monitoring and controls.
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2700 charsUS Department of the Treasury Announces Record Enforcement Actions Against Bank of America for AML and Sanctions Violations
On October 13, 2026, the US Department of the Treasury announced enforcement actions imposing more than US$1.21bn in penalties against Bank of America (BoA) for violations of the Bank Secrecy Act (BSA) and anti-money laundering (AML) and sanctions laws.
The enforcement actions consist of three separate orders from the US Financial Crimes Enforcement Network (FinCEN), US Office of Foreign Assets Control (OFAC) and US Office of the Comptroller of the Currency (OCC), all federal agencies housed within the Treasury.
FinCEN issued a consent order assessing a US$1.2 billion monetary penalty for BoA's failure to mitigate and report priority national security risks, including Chinese money laundering networks and illicit finance along the southwest border of the US. As part of the FinCEN order, BoA admitted to willfull violations of the BSA, and that it failed to:
Implement and maintain an AML program that met the minimum requirements of the BSA and FinCEN’s implementing regulations.
Conduct due diligence for correspondent accounts for foreign financial institutions.
File over US$5m in suspicious activity reports (SARs).
The FinCEN order requires BoA to work with a third party to complete a lookback to identify and report to suspicious transactions that went undetected due compliance failures, as well as undergoing an independent review of the effectiveness of its suspicious activity monitoring, due diligence and data governance framework as it pertains to information used in its AML program.
OFAC, in its enforcement release , announced a US$11.6m settlement agreement with BoA due to 475 violations across numerous sanctions programs, including those on Iran, Russia, narcotics and global terrorism.
According to OFAC, the violations occurred when BoA channeled correspondent banking payments through blocked banks due to technical and human error; allowed sanctioned individuals to make payments and withdraw funds due to poor alert calibration; failed to promptly update watchlists following OFAC designations; and mishandled business accounts associated with blocked persons.
Additionally, the OCC issued a consent order assessing a US$750m monetary penalty against BoA's for its BSA/AML compliance program, which was found to be ineffective. The program's ineffectiveness violated a December 2024 cease and desist order issued by the OCC, which required BoA to address deficiencies in its compliance program.
According to the OCC, this resulted in poor transaction monitoring systems and large numbers of late SARs involving billions of dollars, with the OCC also finding that BoA staff lacked sufficient skills and training to effectively manage its BSA/AML program.