The U.S. Treasury Department announced more than $1.21 billion in penalties against Bank of America on October 13, 2026, over violations of anti-money laundering and sanctions requirements, including failures to report more than $5 billion in suspicious transactions.
The Treasury announcement described the enforcement action as including the third-largest penalty in Treasury history and the largest civil money penalty ever imposed by the Office of the Comptroller of the Currency (OCC).
The Financial Crimes Enforcement Network (FinCEN) assessed a $1.2 billion penalty, including credit for a $750 million OCC assessment. Separately, the Office of Foreign Assets Control (OFAC) reached an $11.66 million sanctions settlement, bringing the combined amount to approximately $1.212 billion.
Bank of America admitted to willful violations of the Bank Secrecy Act as part of its FinCEN resolution, including failures involving anti-money laundering controls, foreign correspondent banking due diligence and suspicious activity reporting.
Bank Failed to Report Billions
According to the FinCEN announcement, Bank of America failed to report more than $5 billion in suspicious transactions on time. More than $1 billion involved national security-related or other priority illicit finance risks.
The transactions included activity indicative of Chinese money laundering networks, potential trade-based money laundering, fraud and illicit financial activity connected to the U.S. southwest border.
Treasury said the bank relied heavily on inquiries from law enforcement and other financial institutions rather than adequately identifying suspicious transactions through its own monitoring systems.
Regulators also found that potentially suspicious transactions remained uninvestigated for extended periods, reducing the usefulness of reports eventually submitted to authorities.
These findings concern failures in detecting, investigating and reporting suspicious activity. They do not establish that every dollar of the transactions involved proven money laundering.
Earlier Compliance Failures Continued
The latest penalties follow an earlier regulatory intervention. On December 23, 2024, the OCC issued a cease-and-desist order requiring Bank of America to address deficiencies in its anti-money laundering and sanctions compliance programs.
That order identified weaknesses in suspicious activity reporting, customer due diligence, internal controls, governance, testing and employee training. Nearly two years later, regulators concluded that significant problems remained unresolved.
The OCC’s October enforcement action found that the bank had failed to adequately monitor trillions of dollars in transactions and continued to experience weaknesses in escalating suspicious activity for investigation.
Regulators also identified insufficient expertise among key compliance personnel and failures in internal audits to detect longstanding problems.
The distinction between the two regulatory actions matters: the 2024 order required corrective measures, while the October 2026 action imposes substantial financial penalties after regulators determined that major deficiencies persisted.
Sanctions Violations Add Further Penalties
Separately, Bank of America agreed to pay $11,662,930 to settle potential civil liability for 475 apparent sanctions violations. The OFAC settlement involved sanctions programs covering Russia, Belarus, Iran, Burma, Somalia, narcotics trafficking and global terrorism.
OFAC identified payments involving blocked banks, deficiencies in sanctions screening, delays in updating watchlists and errors involving accounts associated with blocked individuals.
The agency classified the apparent violations as non-egregious and found that they were largely not voluntarily self-disclosed. The sanctions settlement is legally distinct from the anti-money laundering penalties, although Treasury announced the actions together.
Independent Reviews Required for Bank
Financial penalties are only part of the regulatory response. Under the FinCEN resolution, Bank of America must work with an independent third party to review previously undetected suspicious transactions and submit required reports.
The bank must also undergo independent assessments of transaction monitoring, customer due diligence, foreign correspondent banking controls and the data governance systems supporting its anti-money laundering program.
The distinction between the assessed penalties and the bank’s future obligations is important. The financial settlement addresses identified violations, while the independent reviews are intended to determine whether compliance controls can reliably identify and report risks going forward.
For Bank of America investors, the enforcement raises questions about remediation costs and the effectiveness of the bank’s compliance systems. The findings do not themselves establish a change to customer deposits, account access or the bank’s ability to operate.
The next substantive development will be evidence of whether the required reviews and corrective measures resolve the longstanding deficiencies. Treasury’s October 13 announcement did not provide a public completion date for all those measures.
