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