The smallest of the three Treasury penalties against Bank of America carries the biggest count. The bank agreed to pay $11,662,930 to settle 475 apparent violations of U.S. sanctions programs, the Treasury Department’s Office of Foreign Assets Control, known as OFAC, announced on October 13.
OFAC calls the case non-egregious. The violations ran from September 18, 2021, to April 24, 2025, and involved transactions worth about $14.8 million in total.
What 475 apparent violations look like
Sanctions are U.S. rules that bar banks from handling money for blocked countries, banks and people. “Apparent” violations means OFAC alleges the conduct broke the rules and the bank settled without a court finding. OFAC’s enforcement release splits the 475 into 413 that the bank did not voluntarily disclose and 62 that it did.
The largest group is 403 payments, totaling $14,340,100, that went through 35 blocked banks between February 2022 and March 2025. Thirty-two of those banks were blocked under Russia rules, two under Belarus rules and one under an Iran order. OFAC says some payments went out before the bank’s screening filter was updated, some were false alerts that staff approved, and an alert suppression rule let others through. A longer-term technical fix came in January 2023.
Smaller groups make up the rest. Thirty-one transactions worth $56,258 involved three people on sanctions lists whose exact names and birth dates matched, and the matches were not given priority. The bank fixed that in February 2024. Another 26 transactions, worth $146,543, involved a ship management company designated for global terrorism; the bank updated its watchlist five days late, in February 2025, and told OFAC itself.
The last group involves two business accounts tied to blocked people. In April 2025, $189,869 was moved out of accounts that had a blocked authorized signer. Staff caught the error, blocked the funds and the bank reported it to OFAC.
Most people at Bank of America will never see a sanctions alert on their own account. The question for customers is whether the settlement changes anything for them, and the releases point to no such change. Treasury’s announcement and OFAC’s release do not mention refunds, new fees or any step for account holders. The cases involve payments to or through sanctioned banks and a few accounts linked to blocked individuals.
The next move in Bank of America’s case is the lookback and independent reviews that FinCEN’s consent order demands, and neither Treasury nor the bank has said when they finish.
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Why OFAC set the number where it did
The $11,662,930 matches the base penalty exactly. OFAC calculated that figure as the schedule amount for each violation that was not self-disclosed, plus half the transaction value for each one that was. It applied no reduction.
OFAC listed what pushed the penalty up. It found reckless conduct, including slow screening upgrades, a watchlist gap of more than a month, delayed alert handling and weak staff training. It cited harm to U.S. foreign policy goals, because more than $14 million went to or through blocked banks and most of it was not stopped. It noted that Bank of America is a very large, commercially sophisticated institution and that OFAC had sent it cautionary letters about substantially similar conduct before.
The one mitigating factor was a tolling agreement covering the narcotics-related violations. OFAC found it did not justify any net reduction. The agency also said the bank’s answers during the investigation were piecemeal or incomplete, sometimes over long periods, and that this slowed the case. The bank’s first lookback was narrow, and it disclosed the full scope of the blocked-bank payments only after an OFAC subpoena in January 2025.
The settlement sits inside a bigger Treasury action
The sanctions settlement was announced alongside two other penalties. The Financial Crimes Enforcement Network, known as FinCEN, assessed $1.2 billion, and the Office of the Comptroller of the Currency, known as the OCC, issued a $750 million civil money penalty. Treasury puts the three together at more than $1.21 billion and calls it the third-largest penalty in Treasury history. Treasury says the bank admitted to FinCEN that it willfully violated the Bank Secrecy Act.
Treasury lists the sanctions programs involved as Russia, Belarus, Iran, Burma, Somalia, narcotics and global terrorism. It says the bank also made compliance commitments covering training, testing and audit, and future communication with OFAC. The OFAC recent actions notice lists the settlement at the same $11,662,930.
Treasury Secretary Scott Bessent said in the announcement: “Today’s actions send a clear message that even the biggest financial institutions are not above the law.”
What OFAC tells banks to fix
OFAC’s release ends with a list of lessons for any bank. It says programs need management oversight that “connects the dots” on enterprise-wide patterns, and that repeated similar violations erode confidence in a compliance program. Screening alert rules should be risk-based, supervised and tested often, it says, and a bank stays responsible when a vendor’s screening tool is out of date.
The release also says staff who deal with customers need training on sanctions evasion, and that a bank which investigates quickly, finds the root cause and discloses on its own earns credit. For customers, the useful takeaway is narrow. Payments that touch a blocked bank or person can be stopped or frozen, as the $189,869 in April 2025 was, and the free route for a question about a held payment is the bank’s own compliance or customer service line.
OFAC’s enforcement release is the document to read for the full list of violations and amounts. It does not list the compliance commitments Bank of America made. Treasury’s announcement gives only the general areas.
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This article was produced with AI assistance and reviewed by The Financial Wire’s editorial team.
Warren Cohen is a finance writer based in Phoenix, Arizona, covering personal finance topics including credit, banking, and beginner investing. He earned his degree in business administration from Arizona State University and began his career working in consumer finance, where he gained direct experience with lending and credit systems. He now writes for personal finance websites and fintech platforms, focusing on clear, practical content that helps readers make informed financial decisions.
