OCC: OCC Imposes $750 Million Assessment Against Bank of America for Deficient BSA/AML Compliance

• Bank of America failed to properly monitor trillions of dollars in transactions, resulting in late SARs involving billions of dollars.
• The bank's BSA Officer and staff lacked sufficient skills and expertise, leading to inaccurate and late suspicious activity reports.

The OCC announced a $750 million civil money penalty against Bank of America, N.A. for violations of the Bank Secrecy Act and its implementing regulations, marking the largest penalty in OCC history. The bank is also subject to a December 2024 cease-and-desist order requiring improvements to its BSA/AML compliance program.

Bank of America failed to properly monitor trillions of dollars in transactions, resulting in large numbers of late suspicious activity reports involving billions of dollars. The bank's BSA Officer and staff lacked sufficient skills and expertise, and key personnel did not receive appropriate training, leading to inaccurate and late SARs.

• $750 million OCC civil money penalty
• $1.2 billion FinCEN fine

• Review Bank of America's December 2024 cease-and-desist order (2024 Order) for required remedial actions.
• Assess transaction monitoring systems for gaps that allowed potential trade-based money laundering transactions.
• Evaluate BSA Officer and staff training and expertise deficiencies highlighted in OCC News Release 2026-89.

This story underscores the critical importance of robust BSA/AML compliance for large financial institutions. The OCC’s record penalty and coordinated action with FinCEN highlight regulatory expectations for effective transaction monitoring, timely suspicious activity reporting, and skilled BSA personnel. Compliance officers must ensure their programs address systemic gaps, provide adequate training, and prioritize remediation of deficiencies to avoid similar enforcement actions and protect national and economic security.