OCC imposes record $750 million BSA/AML penalty on Bank of America

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OCC fines Bank of America

Highlights

Bank of America, N.A. faces a record $750 million OCC civil penalty for longstanding BSA/AML violations, including ineffective transaction monitoring and late suspicious activity reporting.
The bank's compliance failures persist over a year after the 2024 order, with systemic gaps exposing billions to potential money laundering and inadequate staff expertise cited.
FinCEN coordinates with the OCC for a total $1.2 billion fine, crediting the OCC's penalty and mandating further remedial action, increasing regulatory pressure on large banks.

Enforcement action targets longstanding compliance failures

As reported by Office of the Comptroller of the Currency, Bank of America, N.A. is being assessed a $750 million civil money penalty for violations of the Bank Secrecy Act and related regulations, including 12 CFR 21.21 and 12 CFR 21.11. The regulator says the bank's BSA/AML compliance program remains deficient and ineffective despite earlier commitments to remediate the issues.

The OCC says the bank's transaction monitoring system fails to properly monitor trillions of dollars in transactions, leading to large numbers of late suspicious activity reports involving billions of dollars. It says many of those delayed filings show signs of potential money laundering, and that the bank knows for years that potentially suspicious activity is not being escalated properly to investigators for review.

According to Comptroller of the Currency Jonathan V. Gould, the bank's internal control breakdowns continue even after it agreed to the 2024 order, despite its scale as the second-largest bank in the U.S. and a globally systemically important institution. The OCC also says the bank's BSA officer and staff lack sufficient skills and expertise, training for key personnel is inadequate, and the audit function fails to identify longstanding concerns later uncovered by examiners.

Coordination with FinCEN raises total regulatory cost

The OCC says Bank of America still does not complete many of the significant steps needed to establish an effective BSA/AML compliance program more than a year after the 2024 order. The regulator cites continued failures to escalate potentially suspicious activity and says the bank processes potential trade-based money laundering transactions because of a systemic gap in its monitoring program.

The action is being taken in coordination with the Financial Crimes Enforcement Network, which is assessing a $1.2 billion fine that credits the OCC's $750 million penalty and also requires remedial action by the bank. The OCC says its assessed penalty will be paid to the U.S. Treasury, underscoring rising regulatory and operational pressure on large banks to strengthen financial crime controls.

In our earlier article on the $1.2 billion Bank of America penalty over AML and sanctions control failures, we outlined regulators’ findings that the bank failed to properly report more than $5 billion in suspicious transactions and remained under a 2024 remediation order. We also described the enforcement package and the requirement for the bank to strengthen monitoring, staffing, and escalation of suspicious activity amid continued deficiencies highlighted by regulators.

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