U.S. Treasury Announces Record Enforcement Actions Against Bank of America

The U.S. Department of the Treasury announced major enforcement actions against Bank of America, imposing multibillion-dollar penalties for failures in anti-money laundering (AML) and sanctions compliance. The actions include a $1.2 billion penalty from the Financial Crimes Enforcement Network (FinCEN), a $750 million civil money penalty from the Office of the Comptroller of the Currency (OCC) - the largest in OCC history - and an $11.6 million settlement with the Office of Foreign Assets Control (OFAC) over apparent sanctions violations involving Iran, Russia, narcotics, and terrorism. Treasury framed the measures as among its most significant, calling out systemic risks to economic and national security and stressing that large institutions are not exempt from AML and sanctions obligations.

FinCEN’s findings describe willful violations of the Bank Secrecy Act, including failures to implement and maintain an adequate AML program, deficient customer due diligence for correspondent accounts of foreign financial institutions, and widespread failures to file suspicious activity reports (SARs). Investigators found that more than $5 billion in suspicious activity went unreported as the bank deprioritized compliance resources, relied on law enforcement and other external inquiries instead of internal automated controls, and allowed suspicious transactions to pile up uninvestigated - resulting in late, low-utility reporting. Treasury emphasized the need for integrated, mutually reinforcing AML/CFT and sanctions controls across financial institutions.