Bank of America’s $1.2 Billion Fine Collects on a 2024 Order

Bank of America will take a $1.2 billion FinCEN penalty after admitting it willfully broke U.S. anti-money laundering law. The Office of the Comptroller of the Currency folded its largest fine ever, $750 million, into that total after finding the bank had not repaired gaps named in a December 2024 order.

The bank said the charge is not tax deductible and will cut third-quarter net income by about 17 cents a share, on results due October 14. Shares fell 1.14% in the October 13 session after the Treasury package landed.

Treasury’s $1.2 Billion Bill Has Three Parts

The U.S. Treasury on October 13 announced more than $1.21 billion in penalties against Bank of America, the second-largest bank in the United States, for anti-money laundering and sanctions failures. FinCEN’s $1.2 billion assessment is the third-largest penalty in Treasury history. It credits the OCC’s $750 million, rather than stacking on top of it. A separate Office of Foreign Assets Control settlement of $11.6 million sits outside that figure.

HOW THE CHECKS STACK

Treasury Secretary Scott Bessent tied the size of the bank to the size of the risk. Bank of America processes hundreds of trillions of dollars a year, a volume Comptroller of the Currency Jonathan V. Gould called a high and rising illicit-finance profile for the sixth-largest bank in the world.

When a bank of this size fails to meet its anti-money laundering and sanctions obligations, the consequences extend far beyond its own walls, exposing the entire U.S. financial system to significant illicit finance risks. Today’s actions send a clear message that even the biggest financial institutions are not above the law.

Scott Bessent, Treasury Secretary, October 13 announcement

The 2024 Order Did Not Close the Gap

This is a second round, not a first warning. On December 23, 2024, the OCC issued a cease-and-desist order for Bank Secrecy Act and sanctions program gaps, including late suspicious activity reports and a customer due diligence flaw the agency said had already been identified. That order required an outside consultant and lookback work. It did not levy a dollar penalty.

FROM THE ORDER TO THE BILL

1. December 23, 2024: OCC issues a cease-and-desist order for BSA and sanctions program failures, with no civil money penalty.
2. October 13, 2026: FinCEN, the OCC, and OFAC announce the penalty package after finding the program still broken.
3. October 14, 2026: Third-quarter results are due, carrying the $1.2 billion non-tax-deductible charge.

Gould said the bank signed that 2024 order and committed to fixing longstanding BSA gaps almost two years ago. The OCC now says the program remains deficient and ineffective. Its monitoring system failed to properly watch trillions of dollars in transfers, which produced large numbers of late SARs involving billions of dollars, many with signs of money laundering.

The bank knew for years it was not sending potentially suspicious activity to investigators for a SAR decision, the OCC said, and did not correct that failure. More than a year after the 2024 order, it still failed to escalate those cases. It also processed potential trade-based money laundering because of a gap in monitoring. Management, the agency said, kept minimizing the program’s weaknesses. Gould called the bank’s response unacceptable and said the largest penalty in OCC history was warranted.

Other Banks Caught What BofA Missed

FinCEN’s investigation did not describe a one-off filing delay. It described a working method. As problems mounted, Bank of America prioritized revenues and held down the hit to compliance resources, Treasury said. It leaned on law enforcement inquiries, requests from other financial institutions, and similar outside interventions instead of its own automated controls.

That choice, Treasury said, meant the bank “effectively outsourced to third parties a substantial portion of its proactive detection and reporting obligations.” Suspicious activity then sat uninvestigated for long stretches, so the reports that did go in were late and of limited use to police. Testing had already flagged the holes. The bank did not make a meaningful change.

Customer due diligence failed in a related way. Profiles did not account for heavy payments from unknown third parties. Staff escalated red flags that pointed to possible narcotics proceeds, trade-based laundering, and fraud, and the bank still did not act in time. As part of the FinCEN resolution, the bank admitted it willfully violated the Bank Secrecy Act by failing to keep a minimum AML program, failing to run required due diligence on foreign correspondent accounts, and failing to file SARs.

Spokesperson Christa Robinson said financial crime compliance is serious and that the bank is responsible for getting it right. In a separate statement the bank said it has invested billions of dollars in technology and dedicated thousands of employees to the work, and that the team is “far along with and committed to completing the work required to address the issues raised by our regulators.” Remediation costs, it said, are already in the current expense base.

What the Unreported $5 Billion Touched

Those failures left FinCEN without timely reports on over $5 billion in suspicious transfers. Over $1 billion of that flow, Treasury said, implicated national security and other priority illicit-finance risks. The consent order now forces a third-party lookback to find activity the bank missed, plus an outside review of monitoring, customer due diligence, foreign correspondent due diligence, and the data that feeds the AML program.

PRIORITY RISKS NAMED IN THE FILE

• Chinese networks: Transfers that FinCEN said were indicative of Chinese money laundering networks.
• Southwest border: Potential trade-based money laundering with a substantial nexus to the southwest border.
• Fraud and narcotics: Red flags on unknown third-party payments, including possible narcotics-trafficking proceeds.
• Lookback tests: Outside reviews must also test how the program handles the southwest border, cartels, Iran, and Russia.

The people who pay the 17-cent hit are shareholders. No senior executive was named as a personal defendant in the civil package, so the earnings charge is the immediate price of a program Gould said management kept downplaying. Customers still face source-of-funds questions on ordinary deposits while the bank, by Treasury’s account, waited for other institutions and for police to tell it what to file.

475 Sanctions Hits Drew an $11.6 Million Check

OFAC’s piece of the package is smaller and classed differently. The office settled Bank of America’s potential civil liability for 475 apparent sanctions violations of programs targeting Russia, Belarus, Iran, Burma, Somalia, narcotics, and global terrorism. The apparent breaches ran from September 18, 2021, through April 24, 2025.

The mechanics were mundane. The bank processed payments involving blocked banks. It failed to push alerts to the front of the queue when a customer was an exact name and date-of-birth match to a blocked person. It did not promptly update watchlists after OFAC designations. Human error mishandled two business accounts tied to blocked persons. Treasury said the result was millions of dollars in payments that appeared to violate those programs.

OFAC called the apparent violations “non-egregious” but largely not voluntarily self-disclosed, and it gave no cut to the base penalty for fixes or cooperation. The $11.6 million is a rounding of that settlement. Training, testing, audit, and future cooperation with OFAC are part of the deal. The contrast with the AML bill is the point regulators are making: screening mistakes on named targets drew a modest check; a program that waited for outsiders to find dirty money drew the record OCC fine and FinCEN’s $1.2 billion.

The Package Stayed Civil, Unlike TD Bank

The October 13 actions are civil penalties from FinCEN, the OCC, and OFAC. That is a different track from TD Bank’s October 10, 2024, resolution, when the firm pleaded guilty to laundering money in a Justice Department case and agreed to combined penalties of $1.8 billion, program fixes, and an independent monitor.

TD had left about $18.3 trillion in activity outside automated monitoring for years, the Justice Department said, and three laundering networks moved funds through the bank. Bank of America’s file, as published, is about late and missing SARs on over $5 billion, weak correspondent due diligence, and a monitoring system that did not keep up with the bank’s own risk. The LSEG mean for adjusted third-quarter earnings sat at $1.10 a share before one-off items, so the 17-cent charge is a visible dent on the print even if it is small next to the firm’s capital.

Other large banks now have a fresh OCC ceiling to price. A $750 million civil money penalty, levied after a prior order with no fine, is the new marker for a program that stays broken. The FinCEN admission of a willful BSA breach will also follow the bank into the next exam cycle, because it is in the settlement, not in a press talking point.

Outside Reviewers Will Reopen Old Transfers

The consent order’s work is the part that outlasts the earnings charge. Bank of America must hire a third party to complete a lookback and report to FinCEN the suspicious transfers that went undetected. It must also sit through independent reviews of the systems that failed.

WHAT THE CONSENT ORDER ADDS

• Lookback: An outside firm must identify and report suspicious activity the bank missed.
• Program tests: Independent review of SAR monitoring, customer due diligence, and foreign correspondent due diligence.
• Data: A review of the data-governance framework that feeds the AML program.
• Priority files: Those reviews are written to test southwest-border, cartel, and narcotics risk, plus Iran and Russia.

Treasury’s own close on the case was a warning to the rest of the industry. Banks cannot treat police inquiries or referrals from other firms as a substitute for internal monitoring, and they cannot park red flags in long internal reviews. Gould said firms that lack an effective BSA/AML program can expect swift and significant OCC action.

The $1.2 billion charge will be in the October 14 results. The lookback will still be running after that print is forgotten, on the same correspondent wires, card flows, and border-linked trade payments the 2024 order was supposed to bring under control.

Frequently Asked Questions

How Is the $1.2 Billion Penalty Split?

FinCEN’s $1.2 billion assessment credits the OCC’s $750 million, so the extra amount FinCEN collects is $450 million. OFAC’s $11.6 million is outside that stack and is paid on top, which is how Treasury reaches more than $1.21 billion in all.

What Did Bank of America Admit in the Settlement?

In FinCEN case 2026-03 the bank admitted willful BSA failures on three fronts: the AML program itself, due diligence on foreign correspondent accounts, and SAR filing. That admission is in the consent order, not a court guilty plea.

What Did the December 2024 OCC Order Require?

The December 23, 2024 cease-and-desist, docketed as AA-ENF-2024-56, carried no civil money penalty. It already required an independent consultant and lookback reviews for missed suspicious activity, which is why the 2026 fine is a second round on the same program.

Do the October 13 Penalties Include a Criminal Charge?

The announced package is civil, from FinCEN, the OCC, and OFAC. TD Bank’s October 2024 resolution, by contrast, included a Justice Department guilty plea and an independent monitor after three laundering networks moved more than $670 million through that bank, the first time a U.S. national bank pleaded guilty to conspiring to launder money.

Disclaimer: This article is news reporting and analysis of a completed regulatory settlement and is for information only. It is not investment advice, a recommendation to buy or sell Bank of America shares, or legal advice about Bank Secrecy Act or sanctions duties. Readers who are considering any action involving the stock, a related security, or a compliance program should consult a qualified financial adviser, attorney, or BSA specialist who can review their own facts. Penalty amounts, earnings figures, and remediation status reflect the Treasury, OCC, OFAC, FinCEN, and company statements cited here as of the article’s date and may change as filings and reviews continue.