In short
- The Office of the Comptroller of the Currency also imposed a $750 million civil money penalty for deficient BSA/AML compliance.
- Bank of America admitted to willfully violating the BSA and failing to file Suspicious Activity Reports.
What happened
FinCEN announced a $1.2 billion penalty against Bank of America, N.A. for failing to address and report priority national security risks, including Chinese money laundering networks and illicit finance along the southwest border. The bank admitted to willfully violating the BSA and not maintaining an adequate AML program.
In addition to FinCEN's action, the Office of the Comptroller of the Currency assessed a $750 million civil money penalty for deficient BSA/AML compliance, and the Office of Foreign Assets Control announced an $11.6 million settlement for apparent violations of sanctions programs related to Iran, Russia, narcotics, and global terrorism.
Bank of America admits that it willfully violated the BSA and 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, and file Suspicious Activity Reports.
In numbers
- $1.2 billion FinCEN penalty against Bank of America
- $750 million OCC civil money penalty
- $11.6 million OFAC sanctions settlement
Named in this item
Organization, regulator US — —
What compliance teams should check
- Review and update AML program controls to meet the minimum requirements of the BSA and FinCEN’s implementing regulations.
- Ensure due diligence is conducted for correspondent accounts for foreign financial institutions, as highlighted in the FinCEN action.
- Assess and improve processes for filing Suspicious Activity Reports, as Bank of America's failures in this area led to enforcement.
Why it matters
This enforcement action underscores the critical importance of robust AML and sanctions compliance programs for financial institutions. The significant penalties imposed by FinCEN, the OCC, and OFAC highlight the risks of failing to address national security threats such as money laundering networks and illicit finance. Compliance officers must ensure their institutions meet all regulatory requirements, conduct thorough due diligence, and file timely Suspicious Activity Reports to avoid similar enforcement actions and reputational damage.
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