{"id":9445,"date":"2026-10-14T16:15:08","date_gmt":"2026-10-14T16:15:08","guid":{"rendered":"https:\/\/senapa.eu\/?p=9445"},"modified":"2026-10-14T16:21:03","modified_gmt":"2026-10-14T16:21:03","slug":"bank-of-america-multa-da-12-miliardi-cosa-e-sfuggito-ai-controlli-antiriciclaggio","status":"publish","type":"post","link":"https:\/\/senapa.eu\/en\/bank-of-america-multa-da-12-miliardi-cosa-e-sfuggito-ai-controlli-antiriciclaggio\/","title":{"rendered":"Bank of America fined 1.2 billion: what slipped through the anti-money laundering checks"},"content":{"rendered":"

On 13 October 2026, the US authorities announced a fine of $1.2 billion against Bank of America for serious breaches of anti-money laundering regulations. The bank, one of the largest in the world, had failed to adequately monitor huge volumes of financial transactions, leaving potentially suspicious transactions without the necessary checks and reporting.<\/p>\n\n\n\n

This case illustrates just how wide the gap can be between having a compliance system in place and ensuring that it actually works.<\/p>\n\n\n\n

Bank of America: why was it fined?<\/h2>\n\n\n\n

TheOffice of the Comptroller of the Currency (OCC)<\/a>, the US federal banking supervisory authority, has imposed a fine of 750 million dollars<\/strong>, the highest ever imposed by the OCC.<\/p>\n\n\n\n

At the same time, the Financial Crimes Enforcement Network (FinCEN), the US Treasury agency responsible for combating money laundering and other financial crimes, has imposed a total fine of $1.2 billion<\/strong>, which already includes the 750 million from the OCC.<\/p>\n\n\n\n

In addition to this, there is a separate $11.6 million settlement with the Office of Foreign Assets Control (OFAC) relating to alleged breaches of international economic sanctions programmes.<\/p>\n\n\n\n

At the heart of the measures lies a specific issue: Bank of America had failed to ensure the effectiveness of the controls required to identify, analyse and report suspicious financial transactions.<\/p>\n\n\n\n

These issues were not new. As early as December 2024, the OCC had ordered the bank to rectify the shortcomings in its anti-money laundering programme. According to the authority, nearly two years later, many significant problems had still not been resolved.<\/p>\n\n\n\n

Over $5 billion worth of suspicious transactions reported late or not reported at all<\/h2>\n\n\n\n

One of the most significant aspects concerns the transaction monitoring system.<\/p>\n\n\n\n

According to FinCEN, these shortcomings led to the failure to identify or the delayed reporting of over 5 billion dollars\u2019 worth of suspicious financial assets<\/strong>.<\/p>\n\n\n\n

To understand the issue, let\u2019s consider how a banking anti-money laundering system works.<\/p>\n\n\n\n

Every day, a bank processes a huge number of transactions. Automated systems must identify anomalous behaviour: transactions that are inconsistent with the customer\u2019s profile, unusual transactions, links to high-risk individuals, or patterns that could potentially be linked to money laundering.<\/p>\n\n\n\n

When a significant anomaly is detected, it must be assessed by qualified staff, who will determine whether further investigation is required and whether the matter should be reported to the authorities.<\/p>\n\n\n\n

In the Bank of America case, the mechanism had significant shortcomings.<\/p>\n\n\n\n

The IT system used risk scores and thresholds to determine which anomalies to refer to investigators. According to the authorities, some of these settings were inadequate and had not been corrected in a timely manner, despite the issues identified during the audits.<\/p>\n\n\n\n

As a result, many suspicious transactions were not investigated thoroughly or were investigated too late.<\/p>\n\n\n\n

An important fact:<\/strong> The figure of 5 billion dollars refers to the value of the suspicious transactions affected by shortcomings in controls and reporting. It does not represent a quantification of money that has been confirmed to have been laundered.<\/p>\n\n\n\n

Almost 200,000 cases awaiting examination<\/h2>\n\n\n\n

The official decision by the OCC<\/a> contains a particularly significant piece of information.<\/p>\n\n\n\n

By 2024, the number of cases awaiting assessment by the bank\u2019s investigators had peaked at almost 200,000 cases<\/strong>.<\/p>\n\n\n\n

This backlog highlights an operational difficulty: identifying an anomaly is not enough if there is no capacity to analyse it in a timely manner.<\/p>\n\n\n\n

The OCC also identified shortcomings in the skills and training of staff responsible for anti-money laundering checks, resulting in reports that were late, incomplete or inaccurate.<\/p>\n\n\n\n

The problem, therefore, concerned both the technology and the organisation of the monitoring activities.<\/p>\n\n\n\n

The case of accounts linked to credit cards<\/h3>\n\n\n\n

One incident described by the inspectors highlights the scale of the problems particularly clearly.<\/p>\n\n\n\n

During an audit of a small sample of accounts from the bank\u2019s credit card portfolio, OCC inspectors identified ten accounts showing possible signs of money laundering through international commercial transactions.<\/p>\n\n\n\n

The authority has asked the bank to investigate those accounts further.<\/p>\n\n\n\n

Following the investigation, Bank of America filed reports concerning hundreds of millions of dollars\u2019 worth of suspicious transactions linked to five of the ten accounts examined.<\/p>\n\n\n\n

According to the OCC, in the absence of a request from the inspectors, there was no indication that the bank would have reviewed those accounts or submitted the relevant reports.<\/p>\n\n\n\n

This is a concrete example of how an anomaly can go unnoticed within normal banking processes and only be identified as a result of an external audit.<\/p>\n\n\n\n

The internal audit had also failed to identify the critical issues<\/h2>\n\n\n\n

Another important aspect concerns the effectiveness of the independent audits carried out by the internal audit function, which is responsible for assessing the adequacy of controls and risk management processes.<\/p>\n\n\n\n

The OCC criticised the internal departments\u2019 failure to identify certain significant weaknesses in the anti-money laundering programme, which were subsequently identified by the inspectors.<\/p>\n\n\n\n

In particular, the Corporate Audit function had failed to effectively verify certain key internal controls and the overall adequacy of the anti-money laundering compliance programme.<\/p>\n\n\n\n

This case highlights an organisational risk: when internal controls fail to identify weaknesses in the processes they are supposed to monitor, these weaknesses can persist for years.<\/p>\n\n\n\n

Having documented procedures, IT systems and regular audits does not, in itself, guarantee that risks are effectively managed.<\/p>\n\n\n\n

It is necessary to verify that the checks produce reliable results and that any anomalies identified are dealt with.<\/p>\n\n\n\n

Has Bank of America been accused of money laundering?<\/h2>\n\n\n\n

A distinction must be drawn between a breach of anti-money laundering obligations and actual participation in money laundering.<\/p>\n\n\n\n

The measures mainly concern the inadequacy of control systems, customer due diligence procedures and processes for reporting suspicious transactions.<\/p>\n\n\n\n

In its settlement with FinCEN, Bank of America acknowledged the breaches of the Bank Secrecy Act alleged by the authority, including breaches classified as wilful under the criteria applicable to civil proceedings. In the OCC order, however, the bank neither admitted nor denied the authority\u2019s findings.<\/p>\n\n\n\n

This does not amount to proving that the bank directly laundered the sums in question or that all the suspicious transactions were in fact unlawful.<\/p>\n\n\n\n

The alleged liability relates to a failure to comply with the obligations regarding prevention, monitoring and reporting laid down in US legislation.<\/p>\n\n\n\n

What lessons does this case hold for banks and businesses?<\/h2>\n\n\n\n

The US authorities have asked Bank of America to take further corrective measures, including a review of past transactions to identify any missing reports and independent audits of the effectiveness of its anti-money laundering controls.<\/p>\n\n\n\n

Regardless of the amount of the fine, this case also offers some useful insights for European organisations.<\/p>\n\n\n\n

An effective prevention system requires that:<\/p>\n\n\n\n