Bank of America Fined $1.2 Billion for AML and Sanctions Failures

On October 13, 2026, the U.S. Department of the Treasury (“Treasury”) and the Office of the Comptroller of the Currency (“OCC”) announced enforcement actions totaling more than $1.2 billion against Bank of America (the “Bank”) for violations of anti-money laundering and sanctions laws. The penalty is the third-largest penalty in Treasury’s history and the largest in the history of the OCC.

The penalties stem from the Bank’s failure to mitigate and report priority national security risks, including Chinese Money Laundering Networks and illicit finance along the southwest border. The penalties also include a civil money penalty for a deficient and ineffective BSA/AML compliance program and a settlement between the Bank and OFAC over apparent violations of sanctions programs covering Iran, Russia, narcotics, and global terrorism.

Treasury’s findings describe systemic breakdowns rather than isolated lapses. Bank of America admitted it willfully violated the Bank Secrecy Act by failing to implement an adequate AML program, conduct due diligence on foreign correspondent accounts, and timely file suspicious activity reports. Treasury also found the Bank relied heavily on law enforcement inquiries and tips from other institutions rather than its own internal controls to detect suspicious activity, effectively outsourcing a substantial portion of its monitoring obligations.

As a takeaway from these penalties, institutions should regularly review their AML and sanctions compliance efforts to ensure they are demonstrably effective. Institutions should be aware that they must be able to identify and act on red flags through their own internal controls rather than relying on external referrals, and customer due diligence must be continuously updated and followed by timely corrective action rather than prolonged internal review.

Full details are available here: https://home.treasury.gov/news/press-releases/sb0657