Three Agencies, One Message: Bank of America’s $1.96 Billion Penalty Is the Cost of Operating on Legacy Compliance

Three Treasury agencies moved against Bank of America in a single coordinated action on October 13, and the structure of the strike tells you more than the dollar figure does. FinCEN assessed $1.2 billion. The OCC added $750 million , its largest penalty in history. OFAC tacked on $11.6 million for 475 sanctions violations. The gross total: approximately $1.96 billion, and the combined FinCEN assessment of $1.2 billion is the third-largest in Treasury history. When three agencies coordinate at this scale, the penalty is not just a punishment.

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