Treasury’s 𝐫𝐞𝐜𝐨𝐫𝐝 𝐁𝐚𝐧𝐤 𝐨𝐟 𝐀𝐦𝐞𝐫𝐢𝐜𝐚 𝐞𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐚𝐜𝐭𝐢𝐨𝐧—no separate campaign name was announced—targets systemic BSA/AML deficiencies and sanctions-screening failures. Treasury reported more than $1.21 billion in penalties, including the third-largest penalty in Treasury history and the largest OCC penalty on record.

𝐄𝐧𝐭𝐢𝐭𝐲

  • 𝐁𝐚𝐧𝐤 𝐨𝐟 𝐀𝐦𝐞𝐫𝐢𝐜𝐚 — Charlotte, North Carolina; the second-largest U.S. bank. Failed to maintain effective transaction monitoring, customer due diligence, suspicious activity reporting, foreign correspondent due diligence, and sanctions controls.

𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐚𝐜𝐭𝐢𝐨𝐧𝐬

  • 𝐅𝐢𝐧𝐂𝐄𝐍: $1.2 billion penalty for willful Bank Secrecy Act violations.
  • 𝐎𝐂𝐂: $750 million civil money penalty for a deficient and ineffective BSA/AML program and failures to remediate issues under a December 2024 cease-and-desist order.
  • 𝐎𝐅𝐀𝐂: $11.6 million settlement covering 475 apparent violations of multiple sanctions programs.
  • Treasury’s release states a combined headline amount exceeding $1.21 billion; the individual agency assessments should not be added without considering any applicable credits or coordinated-resolution terms.

𝐀𝐌𝐋/𝐂𝐅𝐓 𝐟𝐚𝐢𝐥𝐮𝐫𝐞𝐬

  • Failed to timely report more than $5 billion in suspicious transactions to FinCEN.
  • More than $1 billion implicated priority or national-security risks, including Chinese Money Laundering Networks, fraud, potential trade-based money laundering, narcotics-linked activity, and transactions connected to the U.S. southwest border.
  • Improperly relied on law-enforcement inquiries, other banks, and external referrals instead of effective internal detection controls.
  • Allowed suspicious activity to remain uninvestigated for extended periods, producing late SARs of reduced law-enforcement value.
  • Failed to account for customers receiving extensive payments from unknown third parties and did not act meaningfully on escalated red flags.
  • Transaction-monitoring weaknesses affected trillions of dollars in activity and generated late SARs involving billions of dollars.
  • BSA personnel lacked sufficient expertise and training; internal audit failed to identify longstanding deficiencies.
  • Continued significant compliance failures after the December 2024 OCC order.

𝐒𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐬 𝐯𝐢𝐨𝐥𝐚𝐭𝐢𝐨𝐧𝐬

  • Processed millions of dollars in apparent violations of sanctions targeting Russia, Belarus, Iran, Burma, Somalia, narcotics trafficking, and global terrorism.
  • Root causes included:
  • Correspondent payments routed through blocked banks.
  • Poor sanctions-alert calibration permitting designated persons to transact and withdraw funds.
  • Delayed watchlist updates following OFAC designations.
  • Mishandling of business accounts associated with blocked persons.
  • Technical and human errors.
  • OFAC classified the conduct as non-egregious and largely not voluntarily self-disclosed.
  • OFAC granted no reduction from the base penalty, including no mitigation for remediation or cooperation.

𝐑𝐞𝐪𝐮𝐢𝐫𝐞𝐝 𝐫𝐞𝐦𝐞𝐝𝐢𝐚𝐭𝐢𝐨𝐧

  • Conduct a third-party lookback to identify and report previously undetected suspicious transactions.
  • Complete independent reviews of suspicious-activity monitoring, customer due diligence, foreign-correspondent-account due diligence, and AML data governance.
  • Reviews must assess controls addressing the southwest border, cartels and narcotics trafficking, Iran, and Russia.
  • Implement enhanced sanctions training, testing, audit, and future communication and cooperation with OFAC.

𝐂𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞 𝐢𝐦𝐩𝐥𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬

  • Financial institutions must integrate AML/CFT and sanctions controls so they are mutually reinforcing.
  • External referrals cannot substitute for proactive internal monitoring.
  • Customer risk profiles must be updated as activity, products, services, and geographic exposure change.
  • FinCEN’s whistleblower program may provide awards when qualifying information leads to enforcement penalties exceeding $1 million.

Source: https://home.treasury.gov/news/press-releases/sb0657/