The Treasury Department's Financial Crimes Enforcement Network imposed a $1.2 billion penalty, the third-largest in Treasury history, while the Office of the Comptroller of the Currency assessed a $750 million penalty, described as the largest in that agency's history. Treasury separately announced an $11.6 million settlement with the Office of Foreign Assets Control covering 475 apparent sanctions violations.
More than $1 billion of the unreported activity involved national security and other high-priority risks, including Chinese money-laundering networks, fraud and potential trade-based money laundering, including activity connected to the US southwest border, Treasury said.
Bank of America admitted to willful violations of the Bank Secrecy Act, including failing to maintain a compliant anti-money-laundering program, conduct required due diligence on foreign correspondent accounts and file suspicious activity reports. Treasury said the bank prioritized revenue while limiting compliance resources, allowing suspicious activity to remain uninvestigated for extended periods and relying on law enforcement inquiries and referrals from other banks to identify transactions its own systems should have detected. The Comptroller's office found the bank's systems failed to properly monitor trillions of dollars in transactions and that significant deficiencies remained despite a December 2024 order requiring improvements. Technical errors, inadequate screening and delays in updating sanctions lists allowed millions of dollars in payments involving restricted parties under programs concerning Russia, Iran, narcotics and terrorism.
"Today's actions send a clear message that even the biggest financial institutions are not above the law," Treasury Secretary Scott Bessent said. "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."
The bank is required to review past transactions for suspicious activity it previously missed and to undergo independent reviews of its monitoring systems, customer checks and accounts maintained for foreign financial institutions.
Bank of America said it has invested billions in compliance and is "far along" in remediation. It said the penalties will result in a $1.2 billion non-tax-deductible charge in its third-quarter results, reducing net income by about 17 cents per share, with remediation costs already reflected in its current expense base. "Financial crime compliance is serious, and we are responsible for getting it right," spokesperson Christa Robinson said.
The action lands less than a day before the bank reports quarterly earnings on Wednesday morning. Shares were down about 2% in after-hours trading. The penalties renew focus on the record of longtime CEO Brian Moynihan, who took over in 2010 and has emphasized what he calls "responsible growth" after spending his early tenure resolving mortgage-related legal and regulatory matters tied to decisions made before he became CEO.