OCCCivil Money Penaltyhigh

Bank of America

Charlotte, North Carolina

S. regulatory enforcement action over anti-money laundering deficiencies. The disclosure relates to a consent order the OCC issued in December 2024.

The bank stated it is "continuing to discuss a resolution" with the OCC. The filing did not specify the size of any prospective penalty. Bank of America's AML program shortcomings were the basis for the original consent order, and the ongoing discussions point to unresolved compliance gaps.

Implications
  1. Reinforces OCC's willingness to pursue escalating penalties for unresolved AML deficiencies at large banks
  2. Signals heightened AML compliance expectations for banks that serve as sponsors or partners to fintechs
  3. Banks with fintech partnerships must ensure consolidated AML controls account for fintech-originated activity
Sources
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