Current Context: On 13 October 2026, the US Department of the Treasury announced enforcement actions imposing more than $1.21 billion in penalties and a settlement against Bank of America for failures involving anti-money laundering (AML) compliance and sanctions laws. Regulators identified weaknesses in transaction monitoring, customer due diligence and timely reporting of suspicious activity.
Key Points:
- FinCEN Penalty: The Financial Crimes Enforcement Network (FinCEN) assessed a $1.2 billion penalty for failures to detect, mitigate and report illicit-finance risks.
- OCC Penalty: The Office of the Comptroller of the Currency (OCC) imposed a $750 million civil money penalty, its largest-ever penalty.
- Penalty Calculation: The $750 million OCC penalty is credited towards FinCEN’s $1.2 billion assessment. It is therefore not added separately to the total.
- Sanctions Settlement: The Office of Foreign Assets Control (OFAC) announced an additional $11.6 million settlement covering 475 apparent sanctions violations.
- Suspicious Transactions: The bank failed to report more than $5 billion in suspicious transactions on time, including over $1 billion involving national-security and other priority illicit-finance risks.
- Legal Framework: The violations included failures under the Bank Secrecy Act (BSA) concerning AML programmes, foreign correspondent-account due diligence and Suspicious Activity Reports (SARs).
- Corrective Measures: The bank must undertake a review of past transactions and independent assessments of relevant compliance systems.
Question:
Q1. Which US authority imposed its largest-ever civil money penalty of $750 million on Bank of
America?
a) Federal Reserve
b) Securities and Exchange Commission
c) Office of the Comptroller of the Currency
d) Federal Deposit Insurance Corporation
Answer: c) The OCC imposed the $750 million penalty for deficiencies in Bank of America’s BSA/AML compliance programme. This amount is credited towards FinCEN’s $1.2 billion penalty.
