On 13 October, the US Treasury imposed more than $1.2 billion in penalties on Bank of America, the second-largest bank in the United States, for wilful violation of anti-money laundering law. According to Journal du Coin, more than $5 billion in suspicious flows went unreported, or were reported late, over a period of around seven years. This is an administrative sanction by regulators, accompanied by admissions from the bank, and not a criminal conviction: the source specifies that no Department of Justice action targets the institution.
Three authorities, three strands
The case does not fall under a single authority. According to the source, it is FinCEN, the Treasury's anti-money laundering unit, that leads the main strand. In it, Bank of America admits to having wilfully violated the Bank Secrecy Act, the federal law that requires banks to report any suspicious transaction to the authorities. The FinCEN press release also mentions other admissions: a compliance programme that fell short of minimum requirements and deficient controls on accounts opened for foreign banks.
Two other regulators are involved:
- the OCC, the federal regulator of national banks, takes $750 million of this bill, the heaviest penalty in its history according to its own press release;
- OFAC, which is in charge of US economic sanctions, adds $11.6 million for 475 apparent violations involving Russia, Belarus, Iran, Burma, Somalia, drug trafficking and terrorism.
For FinCEN, the amount ranks third in its history, behind Binance (3.4 billion in 2023) and TD Bank (1.3 billion in 2024). Journal du Coin cites the FinCEN press release and reproduces the OCC announcement, but does not provide a direct link to the official decision.
Treasury Secretary Scott Bessent stated that even the largest financial institutions "are not above the law". The head of the OCC, Jonathan Gould, called the bank's response to its own failings "unacceptable".
An alert threshold set too high
At the heart of the case is a piece of software called Event Processor, tasked with screening transactions. It ran from January 2018 to July 2025 with an alert threshold set at 20 risk points. The bank only lowered it to 10 or 12 points in December 2023. The result: more than $5 billion in suspicious transactions were not reported in time, including around $1 billion linked to national security risks.
A retrospective audit carried out in 2024 uncovered nearly 8,900 suspicious activity reports that were never filed, covering some $4 billion. In the United States, this form, the SAR, is the alert that every bank must send to FinCEN when faced with a suspicious flow. Another indication noted by the source: more than a third of internal investigations did not originate from a software alert, but from an outside request (police, subpoena, request from another bank). To absorb the new threshold, the bank estimated that it would need to hire 750 people and bring in 800 consultants.
Specific cases cited
The source details several schemes. Two clients active in online auctions of damaged vehicles deposited tens of billions of dollars in payment instruments between 2020 and 2025; more than $600 million in suspicious money orders were never reported. FinCEN sees this as trade-based money laundering, with money circulating under the guise of sales of goods. Around a third of these flows pointed towards the Mexican border.
A client in the same sector, with around $6 million in annual turnover, received more than $1.7 billion in transfers from countries bordering Russia. Hundreds of millions of dollars in credit card purchases also bore the signature of Chinese money laundering networks, again reported late. Finally, according to CNN as cited by the source, sanctions screening had a flaw: a transaction matching the name and date of birth of a sanctioned person was not handled as a priority.
A penalty some consider modest
The comparison with Binance keeps coming up in the debate. The platform paid $4.3 billion in 2023 and its founder, Changpeng Zhao, spent four months in prison. Bank of America, for its part, faces no prosecution by the Department of Justice, unlike Binance and TD Bank. Dennis Kelleher, head of the NGO Better Markets, considers the fine modest in light of the bank's revenues: "Banks don't break the law, people do."
Bank of America shares fell more than 2.5% in after-hours trading on 13 October, on the eve of the publication of its third-quarter results. A week earlier, the OCC had already imposed $350 million on American Express, whose system had let some 13 billion in suspicious flows slip through for more than ten years.
And in Switzerland?
For a Swiss reader, the question of a parallel with the anti-money laundering obligations of Swiss banks naturally arises. However, the source deals neither with the Swiss framework nor with recent Swiss cases. The two regimes rest on distinct laws, authorities and procedures; this US case therefore does not, on its own, allow any conclusions to be drawn about the situation of institutions in Switzerland.
