The U.S. Department of the Treasury announced on Tuesday coordinated enforcement actions against Bank of America, the second largest bank in the country, totaling over $1.21 billion in penalties for violations of anti-money laundering and sanctions laws, according to the official Treasury statement.
The measures involve three distinct agencies: the Financial Crimes Enforcement Network (FinCEN) imposed a civil penalty of 1.2 billion dollars; the Office of the Comptroller of the Currency (OCC) set a fine of 750 million, the largest in its history, an amount that is credited within FinCEN’s figure and is not added separately; and the Office of Foreign Assets Control (OFAC) agreed to a payment of 11.6 million for 475 alleged violations of multiple sanctions programs.
In terms of actual disbursement, the bank will need to pay 450 million dollars directly to the Treasury within 10 days, plus the 750 million to the OCC, for a total of 1.2 billion in effective payments, according to the FinCEN consent order.
Investigations determined that Bank of America did not timely report to FinCEN over $5 billion in suspicious transactions during the period from January 2018 to July 2025.
Of that total, more than 1 billion were linked to priority national security risks, including Chinese networks involved in money laundering and illegal financial activity related to the U.S. southwest border.
The bank admitted to deliberately violating the Bank Secrecy Act by failing to maintain an anti-money laundering program that met minimum requirements, not conducting due diligence on correspondent accounts of foreign banks, and not submitting suspicious activity reports—known as SARs—accurately and in a timely manner.
A central part of the failures was the bank's proprietary transaction monitoring system, called Event Processor, designed in 2010, which maintained poorly calibrated alert thresholds and static risk weights for years.
When the bank lowered the detection threshold in December 2023, a retrospective review identified nearly 8,900 unfiled SARs, with transactional activity of almost 4 billion dollars, and the bank estimated that it would need 750 additional employees and 800 consultants to handle the volume generated by the new threshold.
This case has a direct precedent: the OCC had already issued a cease and desist order in December 2024 requiring the bank to correct its anti-money laundering program, but more than a year later, the entity was still not escalating potentially suspicious activities to investigators for review.
The FinCEN order also revealed internal communications that illustrate how the bank prioritized revenue over regulatory compliance: in August 2022, compliance staff concluded that "the overwhelming evidence suggests that the client is receiving payments from numerous victims of mass marketing scams," with approximately 90% of more than 125 cases related to fraud, yet the bank chose to maintain the business relationship.
The 475 apparent OFAC violations — classified as non-serious cases — involved transactions linked to Iran, Russia, Belarus, Myanmar, Somalia, drug trafficking, and global terrorism, amounting to approximately $14.8 million, that occurred between September 2021 and April 2025.
The Secretary of the Treasury, Scott Bessent, warned that "when a bank of this size fails to meet its anti-money laundering and sanctions obligations, the consequences extend far beyond its own walls, exposing the entire U.S. financial system to significant risks of illicit financing."
Bank of America publicly acknowledged the seriousness of the deficiencies and stated that it is "far along" in implementing corrective measures, specifying that the charge of $1.2 billion will reduce its net income for the third quarter of 2026 by approximately 17 cents per share.
The FinCEN order also requires independent reviews of the anti-money laundering program, with deadlines extending to July 2028, and a retrospective review of transactions dating back to January 2022, with a final report due no later than December of that same year.
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