The U.S. Department of the Treasury has announced record penalties totalling more than $1.21 billion against Bank of America, the second-largest bank in the United States. The bank will pay the sum for violations of anti-money laundering laws and sanctions regulations.
According to the Treasury, Bank of America failed to report suspicious transactions worth more than **$5 billion** in a timely manner. More than $1 billion of that amount was linked to national security risks and illicit finance, including transactions indicating the involvement of Chinese money laundering networks.
As a result of cooperation with Treasury units, the bank agreed to settle potential civil liability for 475 alleged sanctions violations. According to the Treasury, Bank of America processed payments worth millions of dollars in breach of sanctions against Russia, Belarus, Iran, Myanmar, Somalia, and in violation of terrorism-related restrictions.
The Treasury published the full consent order governing the bank’s liability settlement with FinCEN — the Financial Crimes Enforcement Network, a bureau within the U.S. Department of the Treasury.
What the Consent Order Says
Under the terms of the consent order, FinCEN conducted a civil enforcement investigation and determined that grounds existed to impose a civil money penalty against Bank of America for violations of the Bank Secrecy Act (BSA) and its implementing regulations.
The order states that Bank of America admits to the Statement of Facts and Violations, consents to the issuance of the order, agrees to pay the civil money penalty, and agrees to comply with its provisions, including the undertakings set out in the document.
The conduct described in the order took place from at least January 1, 2018 through July 1, 2025.
Failures in the AML Programme
According to FinCEN, Bank of America willfully failed to implement and maintain an anti-money laundering programme meeting several BSA requirements. The bank’s failures related to several regulatory requirements, commonly referred to as the “pillars” of an AML programme.
The bank willfully failed to implement and maintain adequate internal controls, primarily due to critical deficiencies and gaps in its proprietary transaction monitoring system, known as Event Processor. According to the order, this resulted in both missed and delayed detection and reporting of over $5 billion of suspicious activity**, with roughly **$1 billion of that activity implicating national security-related and other priority illicit finance risks. These included suspicious transactions indicative of Chinese Money Laundering Networks (CMLNs), fraud, and potential trade-based money laundering (TBML) with a substantial nexus to the southwest border.
The order also states that Bank of America’s AML programme deficiencies extended to its customer due diligence (CDD) procedures, including for high-risk customers operating in the online auto auction industry, further contributing to unreported or untimely reported suspicious activity.
Warnings Ignored
According to FinCEN, these violations generally continued throughout the relevant period despite repeated internal warnings from the bank’s own personnel performing compliance and testing functions, as well as external concerns raised by law enforcement and other financial institutions.
The order notes that the bank’s failure to appropriately weight risk factors, even after testing raised concerns, caused failures and delays in identifying and reporting suspicious activity. Event Groups often lingered below the threshold required to trigger an investigation, or expired within the relevant timeframe.
Sanctions Violations
The order also details that Bank of America processed payments in violation of sanctions regimes. According to the Treasury’s announcement, these included violations of sanctions against Russia, Belarus, Iran, Myanmar, and Somalia, as well as terrorism-related restrictions. In total, the bank agreed to settle potential civil liability for 475 alleged sanctions violations.
Record Penalty
The combined penalties of more than $1.21 billion represent one of the largest enforcement actions of its kind. According to the Treasury, the reporting and transparency that financial institutions provide through suspicious activity reports is “essential financial intelligence” used by FinCEN, law enforcement, and others to safeguard the U.S. financial system and combat serious threats — including money laundering, terrorist financing, organised crime, corruption, drug trafficking, and fraud schemes.
The consent order was issued as Number 2026-03 by FinCEN, and Bank of America has agreed to comply with all its provisions, including the undertakings set out in the document.
