Bank of America settles with OFAC for $11,662,930 over 475 apparent sanctions violations
OFAC says Bank of America, N.A. processed payments through blocked banks and for sanctioned people between 2021 and 2025, after screening, alert and watchlist failures. OFAC found the case non-egregious, and most of the apparent violations were not voluntarily self-disclosed.
On October 13, 2026, the US Treasury's Office of Foreign Assets Control (OFAC), which enforces US economic sanctions, announced that Bank of America, N.A. has agreed to pay $11,662,930 to settle its potential civil liability for 475 apparent violations of OFAC sanctions programs. According to OFAC, the apparent violations took place between September 18, 2021 and April 24, 2025, had a total value of approximately $14,834,082, and involved sanctions programs targeting Russia, Belarus, Iran, Burma, Somalia, narcotics and global terrorism.
According to OFAC, Bank of America processed 403 transactions totaling $14,340,100 via 35 blocked banks between February 2022 and March 2025. OFAC also says that exact name and date-of-birth matches to sanctioned people were treated as lower-priority alerts, which allowed three individuals, designated under the Burma, Russia and narcotics kingpin sanctions regulations respectively, to complete 31 transactions totaling $56,258 between September 2021 and February 2024.
According to OFAC, in February 2025 the bank's sanctions watchlist file failed to implement an update, and the bank processed 26 transactions totaling $146,543 on February 7. OFAC also describes human error in handling business accounts linked to blocked persons, including one account that was not restricted until 14 months after the individual was designated, and a transfer of $189,869 into a new, unrestricted account.
OFAC determined that the case was non-egregious. It says Bank of America did not voluntarily self-disclose 413 of the apparent violations and voluntarily self-disclosed 62. OFAC notes that it had previously issued the bank multiple cautionary letters regarding substantially similar conduct. The settlement was announced on the same day as FinCEN's separate $1.2 billion penalty against the bank.
Why it matters to AML professionals
Sanctions screening depends on more than the name list. Alert priority settings, the timing of watchlist updates and the handling of accounts after a customer is designated can each let payments through. AML professionals in sanctions roles need to check that these steps work in practice, not only on paper.
Red flags in this case
- Payments routed through a bank that has recently been added to a sanctions list
- A screening alert showing an exact name and date-of-birth match that is closed or left in a low-priority queue
- Account activity continuing after the account holder or an authorised signer appears on a sanctions list
- Funds moved from a restricted account into a newly opened account shortly after a designation
If this landed in your queue
- Treat any exact name and date-of-birth match to a sanctions list as a high-priority alert and escalate it the same day
- Confirm the screening list in use includes the latest designations before clearing a payment involving a high-risk jurisdiction
- Check whether any party to the payment, including intermediary banks, is on a sanctions list, not only the customer
- If a customer or signer is designated, review all linked accounts and recent transfers, and escalate under your sanctions procedure
What control failed
Sanctions screening. OFAC says Bank of America processed transactions involving blocked banks and designated persons because of screening filter timing, alert prioritization flaws, a watchlist update failure and human error in restricting accounts.
Key terms
- Blocked bank
- A bank whose property and interests are frozen under US sanctions, so US persons generally may not deal with it.
- Non-egregious
- OFAC's label for a case it does not treat as among the most serious, which affects how the penalty is calculated.
- Voluntary self-disclosure
- When a firm reports an apparent sanctions violation to OFAC before OFAC learns of it elsewhere, which can reduce the penalty.
Interview angle
A screening alert shows an exact name and date-of-birth match to a sanctioned person, but the system marked it low priority. What do you do?
Explain that an exact match on strong identifiers should be escalated regardless of system priority, the payment held, and the alert logic reported for review. Mention that alert scoring rules should be tested and audited.
Sources
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