Treasury Hits Bank of America With $1.21 Billion Enforcement Package Over AML, Sanctions Failures

The U.S. Department of the Treasury on Tuesday announced a coordinated enforcement package topping $1.21 billion against Bank of America over anti-money-laundering and sanctions-compliance failures, calling it the third-largest penalty in Treasury history and the largest in the Office of the Comptroller of the Currency’s history. The action targets the nation’s second-largest bank and comes a day before its scheduled third-quarter earnings report.

The package combines actions by three Treasury components. Treasury’s total of more than $1.21 billion reflects a $1.2 billion civil money penalty from the Financial Crimes Enforcement Network, or FinCEN; a credit of $750 million from that amount to a separate OCC penalty; and an $11,662,930 settlement with the Office of Foreign Assets Control, or OFAC. Under FinCEN’s order, Bank of America must pay $450 million to the Treasury within 10 days of the order taking effect, while the $750 million credit goes toward the OCC penalty. That is why the total is roughly $1.21 billion, not the sum of the full FinCEN and OCC figures added together.

FinCEN said Bank of America committed willful violations of the Bank Secrecy Act, the main U.S. anti-money-laundering law for financial institutions, from at least Jan. 1, 2018, through July 1, 2025. According to FinCEN, the bank failed to implement and maintain an adequate anti-money-laundering program, fell short on due diligence for correspondent accounts used by foreign banks, and did not timely file suspicious activity reports, known as SARs, which banks must submit when transactions may involve criminal conduct.

FinCEN said those failures meant the bank did not timely report more than $5 billion in suspicious transactions. About $1 billion of that activity involved national-security and other priority illicit-finance risks, FinCEN said, including Chinese money laundering networks, fraud and trade-based money laundering linked to the southwest border.

Treasury Secretary Scott Bessent said in the department’s announcement that “financial institutions are on the front lines of protecting our economic and national security.” FinCEN’s order said Bank of America “admits to the Statement of Facts and Violations” and agreed to the penalty and other remedial steps.

Separately, OFAC said Bank of America agreed to settle 475 apparent sanctions violations tied to transactions between Sept. 18, 2021, and April 24, 2025, with a total value of about $14.8 million. OFAC said the breakdowns included payments involving blocked banks, sanctions alerts that were wrongly prioritized, delayed updates to sanctions watchlists and human error in handling blocked accounts. OFAC described the apparent violations as “non-egregious but largely not voluntarily self-disclosed.”

The FinCEN order requires Bank of America to undertake a broad remediation program stretching through 2028. That includes hiring third parties to conduct a SAR lookback to identify suspicious activity that may have been missed, as well as independent reviews of suspicious-activity monitoring, customer due diligence, foreign correspondent due diligence and data governance.

The enforcement package adds to an already running compliance matter. FinCEN’s order references a December 2024 OCC consent order that had already required the bank to address deficient Bank Secrecy Act and anti-money-laundering controls. Treasury said Bank of America has roughly $2.7 trillion in assets, underscoring the significance of the case for a systemically important institution as regulators press large banks to tighten defenses against illicit finance. The timing also gives the action immediate relevance for investors, arriving one day before Bank of America is scheduled to report quarterly results.