Treasury fines Bank of America $1.2 billion over money laundering and sanctions failures

Overview

Updated Nov 1

Bank of America recorded a $1.2 billion non-tax-deductible charge in the third quarter for the penalties Treasury announced October 13. In its quarterly filing on October 30, the bank said it has completed major steps under a December 2024 order to fix its anti-money-laundering program and has added staff and technology since late 2023.

Sen. Elizabeth Warren asked the Justice Department on October 29 to open a criminal investigation of the bank. She called the $1.21 billion in fines "a slap on the wrist" and asked Attorney General Todd Blanche to say by November 12 whether the department has investigated the failures or will. A DOJ spokesperson confirmed receiving the letter and declined to discuss investigations.

Why it matters

The required third-party lookback could surface more hidden transactions, extending enforcement and reshaping how major banks monitor customer activity.

Questions about this story

Free account needed to ask — your question is kept and asked for you right after sign-up. Answers are public.

No questions yet — be the first to ask.

Key Indicators

$1.21B

Total penalties announced

Third-largest penalty in Treasury history.

$5B+

Unreported suspicious transactions

Some tied to Chinese money laundering networks and southwest border narcotics flows.

$750M

OCC civil money penalty

Largest penalty in OCC history; FinCEN agreed to credit it against its own penalty.

475

Apparent sanctions violations

Covered by OFAC's $11.6 million settlement.

91¢

Q3 earnings per share

Down from $1.04 a year earlier; the $1.2B charge, equal to 17 cents a share, was booked in the quarter.

$6.9B

Q3 net income

Down from $8.3 billion a year earlier; the bank said the charge pushed its effective tax rate to 22.7%.

Nov 12

DOJ reply deadline

Date Warren set for the Justice Department to answer her questions about a criminal probe.

Voices

Curated perspectives — historical figures and your fellow readers.

People Involved

Scott Bessent

US Treasury Secretary

In office; announced the enforcement actions

Brian Moynihan

Chief Executive Officer, Bank of America

Appeared on CNBC after Q3 earnings, saying the bank is 'on the right course to remediate everything'

Elizabeth Warren

U.S. Senator, D-Massachusetts

Wrote to the Justice Department on October 29 asking for a criminal investigation of the bank; reply sought by November 12

Organizations Involved

Bank of America

Bank

Booked a $1.2 billion charge for the October penalties; says it has completed significant remediation steps under the 2024 OCC order and faces a call for a DOJ criminal probe

The second-largest US bank by assets, headquartered in Charlotte, North Carolina.

Financial Crimes Enforcement Network (FinCEN)

Federal bureau within the US Treasury

Assessed the $1.2 billion penalty against the bank

The Treasury bureau that administers the Bank Secrecy Act and collects suspicious activity reports from financial institutions.

Office of the Comptroller of the Currency

Federal Agency

Issued the largest penalty in its history against the bank

The regulator that charters and supervises national banks.

U.S. Treasury — Office of Foreign Assets Control (OFAC)

US Treasury sanctions office

Settled with the bank for $11.6 million

The Treasury agency that administers and enforces US economic sanctions.

Timeline

December 2024 October 2026

7 events Latest: October 30th, 2026 · 1 week ago

Tap a bar to jump to that date

October 2026
Bank books $1.2 billion charge in quarterly filing
Latest Financial Disclosure

Bank of America's 10-Q recorded a $1.2 billion non-tax-deductible charge for the penalties. Net income fell to $6.9 billion from $8.3 billion a year earlier, and the bank said it has completed significant steps under the December 2024 OCC order, adding personnel and technology since late 2023.
October 30th, 2026
Warren asks DOJ to open a criminal probe
Political Pressure

Sen. Elizabeth Warren wrote to Attorney General Todd Blanche calling the $1.21 billion in fines "a slap on the wrist" and asking whether DOJ has investigated or will investigate the bank's failures. She asked for a reply by November 12.
October 29th, 2026
Bank of America misses Q3 profit estimates
Earnings

Profit fell to $6.9 billion from $8.3 billion a year earlier. EPS of 91 cents missed the $1.10 analysts expected; the $1.2 billion charge, equal to 17 cents a share, was not tax-deductible. Shares fell 7.5% Wednesday morning.
October 14th, 2026
Moynihan says bank is 'on the right course'
Statement

CEO Brian Moynihan told CNBC the bank is 'on the right course to remediate everything' after the fine. CFO Alastair Borthwick told reporters the company is committed to addressing concerns.
October 14th, 2026
Treasury announces $1.21B in penalties
Enforcement Action

FinCEN assesses $1.2B, OCC $750M, OFAC settles for $11.6M over the bank's failures.
October 13th, 2026
Bank flags $1.2B Q3 charge; stock slips 2% after hours
Market Reaction

Bank of America said the penalties will produce a $1.2 billion non-tax-deductible charge in third-quarter results, reducing net income by about 17 cents per share. Shares fell about 2% in after-hours trading.
October 13th, 2026
December 2024
OCC issues cease-and-desist order
Regulatory Action

OCC requires Bank of America to fix its deficient anti-money-laundering compliance program.
December 2024

Scenarios

Bank of America exits OCC consent order by end of 2028

Possible Resolves by End of 2028

Discussed by: Bank compliance analysts and regulators following large-bank consent orders

Bank of America completes the third-party lookback required by the FinCEN consent order and passes independent reviews of its transaction monitoring, customer due diligence, and foreign correspondent account programs. With remediation verified, the OCC terminates the December 2024 cease-and-desist order. Given the scale of the required work, this would likely take until late 2028.

Lookback surfaces new violations, triggering more penalties

Possible Resolves by Q2 2028

Discussed by: Reuters and press coverage of the consent order's requirements

The mandated lookback is designed to catch suspicious transactions the bank missed, and the OCC already found the bank failed to escalate flagged activity for years. If the lookback surfaces substantial additional unreported activity, Treasury or FinCEN could seek new penalties or extend the consent order's requirements. Regulators have previously followed up lookbacks with additional enforcement.

Enforcement drags on past 2028 without resolution

Likely Resolves by End of 2028

Discussed by: Regulators and observers of large-bank AML consent orders

Large banks have historically taken several years to fix anti-money-laundering programs under consent orders, and Bank of America was still behind a year after the 2024 order. The OCC could keep the cease-and-desist order and an outside monitor in place past 2028 if independent reviews find continued deficiencies. This leaves the bank operating under supervision without additional announced penalties.

Justice Department opens a criminal investigation of Bank of America

Possible Resolves by Q1 2027

Discussed by: Sen. Elizabeth Warren, who asked for one; bank enforcement lawyers watching whether a probe follows

Warren has asked DOJ whether it has investigated or will investigate the bank's willful Bank Secrecy Act violations, the standard federal law ties to criminal penalties. Treasury's October announcement described no DOJ resolution, and no deferred prosecution agreement or plea has been announced. Other large banks have faced criminal probes and monitorships after similar admissions.

Historical Context

2 moments from history that rhyme with this story — and how they unfolded.

December 2012

HSBC money laundering settlement (2012)

HSBC paid $1.92 billion to settle charges that it laundered drug money for Mexican cartels and moved funds for sanctioned countries including Iran. The deferred prosecution agreement was the largest such penalty at the time.

Then

HSBC admitted failures and stayed in business under a five-year monitorship rather than facing criminal prosecution.

Now

The case established that mega-banks could pay billions and survive, setting expectations for how regulators handle large institutions.

Why this matters now

The Bank of America penalty uses the same enforcement machinery that produced the HSBC settlement, and is now the third-largest Treasury penalty ever.

December 2022

Danske Bank Estonia scandal (2022)

Danske Bank agreed to pay about $2 billion over roughly $200 billion in suspicious payments flowing through its Estonia branch from 2007 to 2015, much of it from Russia and other former Soviet states.

Then

Danske admitted its branch's anti-money-laundering controls failed for years and exited its Baltic operations.

Now

It became the standard reference for a bank's failure to monitor cross-border flows, and regulators cited it in tightening correspondent banking rules.

Why this matters now

Like Danske, Bank of America failed to detect and report large volumes of suspicious cross-border activity, and now faces a mandatory lookback to find what it missed.