U.S. Regulators Hit Bank of America with Record $1.21 Billion Penalties for AML and Sanctions Failures

The U.S. Treasury Department, through FinCEN, assessed a $1.2 billion penalty against Bank of America on October 13, 2026, for willful violations of the Bank Secrecy Act, including failures to maintain an effective anti-money laundering program and timely file suspicious activity reports (SARs). This represents the third-largest penalty in Treasury history and includes the largest civil money penalty ever imposed by the Office of the Comptroller of the Currency (OCC) at $750 million, credited toward the total. An additional $11.6 million OFAC settlement addressed 475 apparent sanctions violations involving Iran, Russia, narcotics, and terrorism. Bank of America admitted to failing to report over $5 billion in suspicious transactions, with more than $1 billion tied to priority national security risks such as Chinese money laundering networks and illicit finance along the southwest border. Regulators highlighted that the bank prioritized revenues over compliance resources, leading to reliance on external law enforcement inquiries rather than internal controls, and allowed suspicious activity to accumulate uninvestigated. The bank's transaction monitoring system failed to properly oversee trillions of dollars in activity, resulting in late SARs. This action follows a December 2024 OCC cease-and-desist order requiring remediation of BSA/AML deficiencies. The consent order mandates an independent third-party lookback to identify and report previously undetected suspicious transactions, plus reviews of monitoring, due diligence, and data governance programs. These failures expose systemic vulnerabilities in large institutions where scale amplifies risks from inadequate oversight, potentially allowing illicit flows to persist and undermining broader financial system integrity amid rising geopolitical tensions.