> ## Content Index
> Fetch the complete content index at: https://www.theglobalbanker.com/llms.txt
> Use this file to discover other available public pages before exploring further.

# SEC fines Merrill Lynch $7.5 million for suspicious activity report filing failures
- URL: https://www.theglobalbanker.com/sec-fines-merrill-lynch-7-5-million-sar-filing-failures/
- Published: 2026-06-29T13:29:00.000Z
- Updated: 2026-10-02T00:29:46.000Z
- Description: The SEC ordered Merrill Lynch to pay a $7.5 million civil penalty for failing to file numerous Suspicious Activity Reports from April 2020 through September 2024.
- Author: TGB Editorial Team
- Tags: Regulations, Americas

The US Securities and Exchange Commission on Monday censured Merrill Lynch, Pierce, Fenner & Smith and imposed a $7.5 million civil penalty over failures to file numerous Suspicious Activity Reports over a more than four-year period. The order, entered on 29 June 2026 in Administrative Proceeding File No. 3-22652, also directs Merrill to cease and desist from further violations.

The SEC found violations of Section 17(a) of the Securities Exchange Act of 1934 and Rule 17a-8, which require broker-dealers to comply with the SAR filing obligations of the Bank Secrecy Act. The findings cover conduct from April 2020 through September 2024.

#### MONITORING GAPS AT THE CORE

According to the order, Merrill's transaction-monitoring function relied on the Bank of America enterprise Bank Secrecy Act and anti-money laundering programme. The SEC found that Event Groups with risk scores below a threshold of 20 were not promoted for investigation for potential SAR filings.

The absence of investigation of those event groups meant that potentially suspicious transactions in the affected categories were not escalated for review and, where warranted, reported. 

The order said the suspicious activity in the uninvestigated Event Groups related to hundreds of millions of dollars in transactions, and that internal analyses had shown as early as April 2020 that some Event Groups below the risk-score threshold of 20 would, if investigated, result in SAR filings. The suspicious activity included transfers with no apparent lawful purpose, large round-dollar transfers, transfers to or from high-risk locations and cash transactions that appeared to be structured, the order said.

#### SEVEN AND A HALF MILLION DOLLAR PENALTY

The $7.5 million civil penalty accompanies the censure and cease-and-desist order. In accepting the settlement, the SEC considered Merrill's cooperation and remediation, including lowering the case-promotion threshold in December 2023 and a retrospective review that led it to file numerous SARs.

The SEC had previously brought two settled proceedings against Merrill for failing to file SARs, in December 2017 and July 2023, the order notes.

The administrative order is available on the SEC's website. Merrill consented to the order without admitting the findings.

The order defines the relevant period as 8 April 2020 to 10 September 2024.

The order states that, although Merrill relied on Bank of America's enterprise-wide BSA/AML programme, it retained all responsibility for complying with the Bank Secrecy Act and FinCEN requirements.

Administrative Proceeding File No. 3-22652, entered on 29 June 2026, records the censure, the cease-and-desist order and the $7.5 million civil penalty in a single settled action.