OCCCivil Money Penaltycritical

Bank of America, N.A.

Charlotte, NC

11. The penalty is the largest in OCC history.

Bank of America is also subject to a December 2024 cease-and-desist order requiring it to address deficiencies in its BSA/AML compliance program. The bank is the second-largest in the United States and the sixth-largest in the world, processing hundreds of trillions of dollars in transactions annually.

Implications
  1. Demonstrates willingness of regulators to impose billion-dollar-plus coordinated penalties for BSA failures
  2. Raises the compliance bar for all banks, including BaaS sponsor banks that process high volumes of transactions through fintech partners
  3. Multi-agency coordination signals an enforcement model that may be applied to sponsor bank-fintech relationship failures
Source
Related
Share