Daily Compliance Brief — FinCEN Hits Bank of America With $1.2 Billion AML Penalty

October 14, 2026

Signal

FinCEN announced on October 13, 2026, a $1.2 billion penalty against Bank of America, N.A. for failing to mitigate and report priority national security and illicit finance risks. According to FinCEN’s enforcement announcement, the bank admitted to willful Bank Secrecy Act violations, including deficiencies in its AML programme, correspondent account due diligence, and suspicious activity reporting.

The U.S. Treasury’s coordinated enforcement package also included a $750 million civil penalty from the Office of the Comptroller of the Currency and an $11.6 million settlement with the Office of Foreign Assets Control over apparent sanctions violations. Treasury stated that the bank failed to report more than $5 billion in suspicious transactions, including activity linked to Chinese money laundering networks, potential trade-based money laundering, and risks along the U.S. southwest border.

Why it matters

The findings expose the operational consequences of relying on external referrals instead of effective internal detection and escalation. Financial institutions should test whether transaction monitoring identifies suspicious activity independently, whether alerts are investigated promptly, and whether reporting decisions are supported by documented analysis.

Correspondent banking due diligence, customer risk profiles, and sanctions screening also require attention where customer activity, third-party payment flows, or changing sanctions lists create new exposure. The required independent reviews and transaction lookback reinforce the importance of data governance, appropriately trained staff, and audit processes capable of identifying persistent control failures.