Bank of America has just been charged with “willfully” violating anti-money laundering and sanctions laws, in failing to report more than $5 billion in “suspicious” transactions… more than $1 billion of that was tied to what Treasury calls “priority” national-security risks, including Chinese money-laundering networks and illicit finance along the southwest border.
This is the same Bank of America that received a $45 billion TARP bailout loan from the U.S. Treasury in January 2009. And, another $91.4 billion from the Fed during the great financial crisis…
Bloomberg: Bank of America was the #3 recipient via the Fed’s ‘Secret Liquidity Lifeline’ infusions with $91.4 billion (peak loan amount – 2/26/2009).
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ZeeoHedge, Oct 13, 2026 – Excerpts:
…Just after the close on Tuesday, Treasury announced more than $1.21 billion in penalties against BofA for violating anti-money-laundering and sanctions laws. Treasury calls it the third-largest penalty in its history, and the OCC calls its piece the largest it has ever handed out. The bank admitted it willfully violated the Bank Secrecy Act. It did not report more than $5 billion in suspicious transactions on time, and more than $1 billion of that was tied to what Treasury calls “priority” national-security risks, including Chinese money-laundering networks and illicit finance along the southwest border.
Here is how the money breaks down, per Treasury’s press release:
The Financial Crimes Enforcement Network (FinCEN) assessed a $1.2 billion penalty for the Bank’s failure to mitigate and report priority national security risks, including Chinese Money Laundering Networks and illicit finance along the southwest border.
The OCC assessed a $750 million civil money penalty for the Bank’s deficient and ineffective BSA/AML (anti-money laundering) compliance program.
The Office of Foreign Assets Control (OFAC) announced an $11.6 million settlement agreement with the Bank over apparent violations of numerous sanctions programs, including on Iran, Russia, narcotics, and global terrorism….
“Prioritized Its Revenues”
….As these issues arose, Bank of America prioritized its revenues and minimized the impact on its required compliance resources. The nature and extent of the Bank’s resulting reliance on law enforcement inquiries, requests by other financial institutions, and similar interventions over its own internal, automated controls… meant that the Bank effectively outsourced to third parties a substantial portion of its proactive detection and reporting obligations.
Translation: BofA’s money-laundering detection system often amounted to waiting for a subpoena.
Treasury also says the bank “allowed suspicious activity to accumulate uninvestigated for extended periods.” That meant SARs arrived too late to help law enforcement much. Its customer due diligence also “failed to account for customers’ extensive reliance on payments from unknown third parties,” and the bank didn’t act on red flags that included “potential ties to narcotics trafficking proceeds,” even after its own compliance staff raised concerns about trade-based money laundering and fraud.
The OCC’s language was harsher. Its release says the bank’s transaction monitoring “resulted in the Bank failing to properly monitor trillions of dollars in transactions,” that “the Bank knew for years” it was failing to escalate potentially suspicious activity, and that its BSA Officer and staff “lacked sufficient skills and expertise.” Comptroller Jonathan Gould said:
“The second largest bank’s egregious and continued BSA violations warrant the OCC imposing its largest [civil money penalty] ever assessed against a bank.”
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OFAC, for its part, found 475 apparent sanctions violations. They included payments routed through blocked banks and designated individuals who were allowed to withdraw funds “due to poor sanctions alert calibration.” OFAC called the violations “non-egregious,” which is the regulatory version of “could have been worse.”
About That 2024 Order
None of this came out of nowhere. On December 23, 2024, the OCC issued a cease-and-desist order against BofA for BSA and sanctions deficiencies, “including a failure to timely file suspicious activity reports and failure to correct a previously identified deficiency related to its Customer Due Diligence processes.” The order itself described a “systemic failure” to set proper transaction-monitoring thresholds. That order came with no fine, a point American Banker noted at the time….
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A look back…
Fall 2008: Bank of America – #3 Recipient of Fed’s “Secret Liquidity Lifelines”
Bank of America – the story behind the story (Source: Bailout Nation)
June 2005: Bank of America takes a 9 percent stake in China Construction Bank for #3 billion; China’s market tops out in 2007 and then plummets 72 percent.
January 2006: Bank of America acquires MBNA for $35 billion. The world’s largest issuer of credit cards [MBNA] is taken over right before the world’s largest credit crunch occurs and (whoops) just before the worst postwar recession begins.
August 2007: Bank of America invests $2 billion in Countrywide Financial, the nation’s biggest mortgage lender and loan servicer. It is a jumbo loser, dropping 57 percent in a few month’s time
January 2008: Bank of America doubles down and announces a $4.1 billion acquisition of Countrywide. The timing is flawless, and the purchase is announced as the worst housing collapse in modern history is accelerating.
September 2008: Bank of America pays $50 billion for Merrill Lynch, including Merrill’s portfolio of toxic assets (along with some previously unannounced trading desk errors).
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Note – following the above cited BofA follies, the Treasury Department and the Federal Reserve stepped up to the plate and kindly dished out billions of dollars (at U.S. citizen taxpayer expense) to Bank of America to keep the big boat afloat.
To recap (Source: Bloomberg Nov 28, 2011 ): Morgan Stanley was the #1 recipient of Fed secret loans at $107 billion (peak loan amount – 9/29/2008).
Citigroup was the #2 recipient of the Fed’s secret lifelines $99.5 billion (peak loan amount – 1/20/2009).
Bank of America was the #3 recipient with $91.4 billion (peak loan amount – 2/26/2009).
Bloomberg Nov 28, 2011: “Bank of America Corp., which got two rounds of U.S. Treasury Department capital injections totaling $45 billion to stay afloat during the credit crisis, borrowed twice that amount in secret from the Federal Reserve. On Feb. 26, 2009, the Charlotte, North Carolina-based bank held $78 billion of loans from the Fed’s Term Auction Facility, $8.65 billion from the Primary Dealer Credit Facility, $4.75 billion from the Term Securities Lending Facility. The financing helped bolster the largest U.S. bank by assets as investors worried its 2008 acquisitions of Merrill Lynch & Co. and Countrywide Financial Corp. might lead to nationalization.”
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A final question: Is there anyone who still believes that it is OK for major Wall Street banking and financial services institutions to receive massive liquidity injections (at taxpayer expense) when their financial viability evaporates … due to their own failed risk management strategies and reckless, yield-driven investment decision-making….
But it is not OK for U.S. citizens to be accorded the same access to direct liquidity extensions?
It is time now to level the playing field… and activate a Federal Reserve / U.S. Treasury pipeline via a U.S. Citizens Credit Facility.
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