OCC puts a record $750 million penalty on Bank of America with its 2024 order still unfinished
OCC says its $750 million penalty on Bank of America, N.A. for Bank Secrecy Act violations is the largest in its history. FinCEN's parallel $1.2 billion fine credits that amount, so the two actions together total $1.2 billion.
The Investor · Invest desk
Share bar: the OCC's $750 million civil money penalty on Bank of America, N.A. is shown as part of FinCEN's $1.2 billion fine, which credits the OCC's penalty and requires remedial action by the bank.
- OCC penalty within FinCEN fine, claim 3 $750 million of $1,200 million 63% computed
OCC penalty within FinCEN fine The whole
| Share | Part | Whole | Percent | Claim |
|---|---|---|---|---|
| OCC penalty within FinCEN fine | $750 million | $1,200 million | 63% (computed) | 3 |
What happened
- The bank is also under a December 2024 cease-and-desist order that requires it to fix its deficient BSA/AML compliance program.
- The OCC found a deficient monitoring system left trillions of dollars in transactions improperly monitored and produced late suspicious activity reports involving billions of dollars.
- The bank's BSA audit function missed long-standing concerns that examiners later uncovered.
Why it matters
- precedent The OCC followed a signed order with a record penalty and a parallel FinCEN action. A bank that has left steps of its own order unfinished can now see what the OCC may do next.
- cost On top of the fines, the bank still owes the work the 2024 Order requires and the remedial action FinCEN is imposing, and that spending falls on its own compliance budget.
- decision Boards of banks under open BSA orders must decide whether remediation milestones outrank other spending, because the OCC's case rests on what the bank left unfinished after signing.
Adding the two penalties gives the wrong total. FinCEN is assessing $1.2 billion and credits the OCC's $750 million against it [3], so the second action adds $450 million [15], or 37.5% of FinCEN's figure [16]. A reader who stacked the two would overstate the bill at $1.95 billion [17]. The OCC's $750 million goes to the U.S. Treasury [4].
The sequence is the part of the case the OCC documents best. Comptroller Jonathan Gould said: "Almost two years ago, the bank signed an order with the OCC and committed to fixing its longstanding BSA deficiencies." [12] The OCC says the bank did not complete many of the significant steps needed to build an effective program [6], and that it knew for years that potentially suspicious activity was not reaching investigators [8]. It also says the BSA Officer and staff lacked sufficient skills and expertise, and that key personnel were not trained to identify, investigate and report suspicious activity [10]. Those findings describe capacity the bank had not built: people who could escalate alerts, training for the people who file the reports, and a monitoring gap that let trade-based transactions through.
"Sharply" is harder to show than "after a stall". The release did not disclose the previous OCC record, whether the 2024 Order carried a penalty, or a response from Bank of America. The record status rests on the OCC's own statement [18].
Other readings fit the same facts. The number may be scaled to this bank, which the OCC calls the second largest in the U.S. and says processes hundreds of trillions of dollars in transactions every year [14]; a smaller bank in the same position would then face a smaller number. Or it may be a one-off for a bank the OCC says ignored a known problem for years [8]. Or, since FinCEN's credit leaves $450 million of added cash [15], the remedial requirements may change more at a bank this size than the extra fine does.
We think the stalled-remediation reading holds, though only for banks already under an order. Gould said: "The OCC expects all banks to have an effective BSA/AML compliance program. Those that do not can expect swift and significant action from the OCC." [13] A record-sized penalty on a bank with no prior order would show that the order was not what drove this number. So would a small penalty on a bank that stalled after signing one.
What to watch
- The terms of FinCEN's remedial action, which the OCC announcement mentions but does not describe.
- Any Bank of America disclosure or response on the penalties and on its progress under the 2024 Order.
- Whether the OCC amends, extends or terminates the December 2024 order after the penalty.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence72
- Adoption
- Insufficient
- Hype gap+8
- Incentives55
- Confidence70
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
The OCC announced a $750 million civil money penalty against Bank of America, N.A., for violations of the Bank Secrecy Act and its implementing regulations, including 12 CFR 21.21 and 12 CFR 21.11.
- [2]
Bank of America, N.A. is also subject to a December 2024 cease-and-desist order that requires it to address its deficient BSA/AML compliance program.
- [3]
FinCEN, acting in coordination with the OCC, is assessing a $1.2 billion fine that credits the OCC's $750 million penalty and requires remedial action by the bank.
- [4]
The OCC-assessed penalty will be paid to the U.S. Treasury.
- [5]
The OCC says that more than a year after the 2024 Order, the bank still failed to escalate potentially suspicious activities to investigators for review.
- [6]
The OCC says that after agreeing to the 2024 Order the bank still failed to prioritize BSA/AML compliance and did not complete many of the significant steps needed to establish an effective program.
- [7]
The OCC found that a deficient transaction monitoring system left the bank failing to properly monitor trillions of dollars in transactions and caused it to file large numbers of late suspicious activity reports involving billions of dollars; many of the late reports had indicia of money laundering.
- [8]
The OCC says the bank knew for years that it was failing to escalate potentially suspicious activities to investigators for review but failed to correct the violation.
- [9]
The OCC says the bank processed potential trade-based money laundering transactions due to a systemic gap in its transaction monitoring program.
- [10]
The OCC says the bank's BSA Officer and staff lacked sufficient skills and expertise, and key BSA personnel did not receive appropriate training on suspicious activity identification, investigation and reporting.
- [11]
The OCC says the bank's BSA audit function failed to identify long-standing BSA concerns that examiners subsequently uncovered.
- [12]
"Almost two years ago, the bank signed an order with the OCC and committed to fixing its longstanding BSA deficiencies."
- [13]
"The OCC expects all banks to have an effective BSA/AML compliance program. Those that do not can expect swift and significant action from the OCC."
- [14]
The OCC describes Bank of America, N.A. as the second largest bank in the U.S. and says it processes hundreds of trillions of dollars in transactions across the globe every year.
- [15]
FinCEN's fine adds $450 million beyond the OCC's penalty.
- [16]
The $450 million increment is 37.5% of FinCEN's $1.2 billion fine.
- [17]
Stacking the OCC and FinCEN amounts without the credit would give $1.95 billion.
- [18]
The OCC says the $750 million amount is the largest in OCC history.
Sources
2 independent publishers whose own reporting we read for this story.
- americanbanker.comBofA gets $1.21B penalty for money laundering
1 article · October 13, 2026
- crowdfundinsider.comOCC Imposes $750 Million Assessment Against Bank of America for Deficient BSA/AML Compliance
2 articles · October 13, 2026
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Topics
- Bank Secrecy Act enforcementFollow
- Anti-Money-Laundering ComplianceFollow
- Bank RegulationFollow