FinCEN Assesses $1.2 Billion Penalty against Bank of America

Bank of America enforcement creates concrete demand for outside investigations. FinCEN assessed a $1.2 billion penalty, crediting the OCC’s $750 million assessment; OFAC separately announced an approximately $11.7 million settlement. FinCEN identified failures involving Chinese laundering networks, southwest-border illicit finance, correspondent-account diligence, and suspicious-activity reporting. OFAC cited delayed watchlist updates and mishandled screening alerts.

The consent order requires independent consultants for historical transaction reviews, monitoring effectiveness, customer/correspondent diligence, and data governance. Border, cartel, and narcotics risks are explicit priorities; network analysis is among the contemplated methods.