The US Treasury announced enforcement actions on October 14 imposing more than $1.21 billion in penalties on Bank of America for failures involving anti-money-laundering controls and sanctions compliance. Treasury described the combined outcome as its third-largest penalty and the largest penalty in the history of the Office of the Comptroller of the Currency.
The Financial Crimes Enforcement Network said Bank of America admitted willful violations of the Bank Secrecy Act. According to Treasury, the bank failed to maintain a compliant anti-money-laundering program, perform required due diligence on correspondent accounts for foreign financial institutions and submit suspicious activity reports. Investigators identified weaknesses in both customer due diligence and the systems used to detect and report questionable transactions.
Treasury said those shortcomings caused the bank to report more than $5 billion in suspicious transactions late. More than $1 billion of that activity involved national-security or other priority illicit-finance risks, including signs associated with Chinese money-laundering networks, fraud and potential trade-based laundering connected to the southwest border. The enforcement account says concerns were escalated internally, but the bank did not respond promptly or adequately.
Under FinCEN’s consent order, Bank of America must hire an outside party to conduct a lookback for transactions that its deficient controls failed to detect. It must also submit to independent reviews of suspicious-activity monitoring, customer due diligence, foreign correspondent-account controls and the data governance supporting its compliance program. Those reviews will examine how the bank handles priority risks related to the southwest border and cartels, as well as Iran and Russia.
The OCC action addresses Bank Secrecy Act violations and follows a cease-and-desist order issued in December 2024. Treasury said the bank’s monitoring system failed to scrutinize trillions of dollars in transactions effectively, generating large numbers of late reports involving billions of dollars. It also said relevant staff lacked necessary expertise and training, while internal audit did not identify problems later found by examiners.
A separate Office of Foreign Assets Control settlement covers potential civil liability for 475 apparent sanctions violations. Treasury attributed those incidents to a combination of technical and human errors, poorly calibrated alerts and delays in updating sanctions watchlists. The described conduct included processing correspondent payments through blocked banks and allowing designated people to make payments or withdraw money.
The resolution places remediation obligations alongside the financial penalties. Its central requirement is that Bank of America rebuild detection, escalation and reporting systems capable of identifying suspicious activity without depending heavily on law-enforcement inquiries or warnings from other financial institutions.
