The Office of the Comptroller of the Currency issued a Cease and Desist Order against Bank of America, N.A. on 23 December 2024, citing violations and unsafe and unsound practices in the bank's Bank Secrecy Act, anti-money-laundering, and sanctions compliance programmes. The order requires the bank to take corrective action to address the identified deficiencies.
The OCC identified two principal failings at the core of the enforcement action: the bank's failure to file suspicious activity reports in a timely manner as required under the BSA, and its failure to correct a customer due diligence deficiency that had been identified in a prior supervisory examination. The failure to correct a previously identified CDD deficiency is one of the violations cited in the Cease and Desist Order, a formal enforcement tool that carries obligations enforceable in court if the bank fails to comply.
GOVERNANCE AND CONTROLS FOUND INADEQUATE
Beyond the specific SAR filing and CDD failings, the OCC's action documented broader deficiencies in Bank of America's internal controls, governance arrangements, independent testing processes, and the training provided to staff responsible for financial crime compliance.
As part of the order, the OCC required Bank of America to engage an independent consultant to conduct an assessment of its BSA/AML and sanctions programmes. The independent consultant will also be required to carry out lookback reviews covering suspicious activity that may not have been identified and reported within the required timeframes during the period when the bank's controls were operating below the expected standard.
NO CIVIL MONEY PENALTY
The OCC did not impose a civil money penalty as part of the 23 December action.
Bank of America, N.A. is one of the largest federally chartered banks in the United States by total assets.