OCC BSA/AML Supervision Brief

Headline

OCC imposes record $750 million civil money penalty on Bank of America for BSA/AML program failures

Executive Summary

The OCC imposed a $750 million civil money penalty against Bank of America, N.A. on October 13, 2026, the largest in OCC history, for violations of the Bank Secrecy Act and its implementing regulations. FinCEN separately assessed $1.2 billion, crediting the OCC penalty against that total. The bank also remains subject to a December 2024 cease-and-desist order requiring remediation.

Bottom Line

The OCC imposes a $750 million civil money penalty on Bank of America, N.A., the largest in OCC history, for BSA/AML violations including deficient transaction monitoring, late and inaccurate suspicious activity report filings, and inadequate BSA officer expertise. The bank remains subject to the December 2024 cease-and-desist order, and FinCEN's coordinated $1.2 billion assessment, which credits the OCC penalty, requires additional remedial action. The Comptroller's public statement explicitly frames the OCC's expectation of effective BSA/AML programs at all banks and warns of swift and significant consequences for deficiency. Cresthaven reading: the record penalty against a globally systemically important bank, paired with the Comptroller's industry-wide warning, places BSA/AML program adequacy, particularly transaction monitoring systems, SAR escalation controls, and BSA officer qualification, as an active enforcement exposure across the national bank population.

Key Regulatory Signals

• Record Civil Money Penalty: The OCC assessed $750 million against Bank of America, N.A., the largest civil money penalty in OCC history, for BSA/AML program violations. The penalty is payable to the U.S. Treasury.
• Coordinated FinCEN Action Compounds Exposure: FinCEN is separately assessing a $1.2 billion fine that credits the OCC's $750 million penalty and requires additional remedial action by the bank. The two actions together represent a coordinated federal enforcement posture against a single institution's BSA/AML failures.
• Cease-and-Desist Order Remains in Force: The bank is subject to a December 2024 cease-and-desist order that requires it to address deficiencies in its BSA/AML compliance program. The OCC found that more than a year after that order, the bank still failed to escalate potentially suspicious activities to investigators for review.
• Systemic Program Failures Identified: The OCC found that the bank's deficient transaction monitoring system caused it to fail to properly monitor trillions of dollars in transactions, resulting in large numbers of late suspicious activity reports involving billions of dollars, many with indicia of money laundering. The bank also processed potential trade-based money laundering transactions due to a systemic gap in its monitoring program.
• Explicit Industry-Wide Warning Issued: Comptroller Jonathan V. Gould stated that the OCC expects all banks to have an effective BSA/AML compliance program and that those that do not can expect swift and significant action. Cresthaven reading: this language, paired with the record penalty against a globally systemically important bank, places every national bank's BSA/AML program posture within the OCC's stated enforcement frame.

Regulatory Delta

• At $750 million, this penalty is the largest civil money penalty the OCC has ever imposed, marking a clear escalation from prior BSA/AML enforcement actions against large institutions.
• The coordinated OCC-FinCEN structure, where FinCEN's $1.2 billion assessment credits the OCC penalty, reflects an inter-agency enforcement model that expands total institutional exposure beyond what any single regulator could impose alone.
• The Comptroller's explicit public warning to all banks signals an active enforcement posture on BSA/AML program adequacy across the national bank population. This is consistent with FinCEN's own heightened examination and enforcement priorities under the Anti-Money Laundering Act of 2020.

Materiality Classification

HIGH — The OCC's record civil money penalty against a globally systemically important bank is accompanied by an explicit Comptroller statement framing BSA/AML program adequacy as an expectation for all banks, with a stated warning of swift and significant action for deficiency, satisfying the sector-wide actionability and systemic-institution anchor tests.

Intelligence Outlook

Monitor the OCC and FinCEN for follow-on enforcement actions against other national banks under this coordinated BSA/AML enforcement posture, and for any updated supervisory guidance on transaction monitoring and SAR escalation standards.