In short
- Regulators found the bank failed to report more than $5 billion in suspicious transactions, including $1 billion tied to priority risks.
- The OCC imposed a $750 million penalty, its largest ever, credited toward FinCEN’s $1.2 billion penalty.
What happened
Bank of America was fined more than $1.21 billion by U.S. authorities for failing to detect and report suspicious financial activity, including Chinese money-laundering networks and activity along the U.S. southwestern border. FinCEN assessed a $1.2 billion penalty, and the OCC imposed a $750 million penalty, the largest in its history, credited toward FinCEN’s penalty.
The bank admitted to willfully violating the Bank Secrecy Act, failing to maintain an adequate AML program, and not conducting required due diligence on correspondent accounts for foreign banks. OFAC also settled for $11.66 million over 475 apparent sanctions violations involving Russia, Belarus, Iran, Myanmar, Somalia, narcotics trafficking, and global terrorism.
Financial crime compliance is serious, and we are responsible for getting it right,” a spokesperson said, adding that the bank has invested billions of dollars in technology and assigned thousands of employees to combat financial crime.
In numbers
- $1.21 billion total penalties imposed
- $5 billion suspicious transactions not reported
- 475 apparent sanctions violations
Named in this item
What compliance teams should check
- Review Bank of America’s remediation measures required by FinCEN and OCC for AML program deficiencies.
- Assess exposure to Chinese money-laundering networks and activity along the U.S. southwestern border as flagged in the enforcement action.
- Update sanctions screening processes to address failures cited in OFAC’s settlement, including prioritizing alerts and timely watchlist updates.
Why it matters
This enforcement action highlights the critical importance of robust AML and sanctions compliance programs, especially for large financial institutions. The penalties and findings underscore the risks of failing to detect and report suspicious activity, including cross-border money-laundering networks and sanctioned entities. Compliance officers must ensure their institutions’ transaction monitoring, due diligence, and sanctions screening processes are effective and responsive to regulatory expectations, as deficiencies can result in substantial financial and reputational consequences.
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