The Office of the Comptroller of the Currency has imposed a $750 million civil money penalty against Bank of America, N.A. for violations of the Bank Secrecy Act and its implementing regulations, including 12 CFR 21.21 and 12 CFR 21.11. The OCC said this is the largest civil money penalty in its history.
The action follows a December 2024 cease-and-desist order requiring the bank to address deficient Bank Secrecy Act/anti-money laundering compliance. Comptroller of the Currency Jonathan V. Gould said Bank of America is the second-largest U.S. bank and sixth-largest globally, processing hundreds of trillions of dollars in transactions each year, with a high and increasing risk profile for money laundering, terrorist financing and other illicit activities.
The OCC found the bank's transaction monitoring system was deficient, failing to properly monitor trillions of dollars in transactions and causing large numbers of late suspicious activity reports involving billions of dollars. The bank also failed for years to escalate potentially suspicious activities to investigators, had BSA personnel lacking sufficient skills and training, and its BSA audit function missed long-standing concerns. More than a year after the 2024 order, the bank still failed to escalate suspicious activities and had a systemic gap that allowed potential trade-based money laundering.
The OCC coordinated with the Financial Crimes Enforcement Network, which is assessing a $1.2 billion fine that credits the OCC's $750 million penalty and requires remedial action by the bank. The OCC-assessed penalty will be paid to the U.S. Treasury.
