Enforcement lessons
What Community Banks Can Learn from Bank of America’s Consent Order
Six practitioner lessons from a $1.2 billion BSA action, and what to do about them this quarter
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$1.2 billionFinCEN civil money penalty
$750 millionOCC assessment, credited by FinCEN toward its fine
$11.6 millionOFAC settlement of roughly 475 apparent sanctions violations
$5B+in suspicious activity the bank missed or filed late on
At a glance
The action
FinCEN, the OCC and OFAC announced coordinated actions against Bank of America on October 13, 2026.
The reader
Written from the BSA Officer chair for institutions much closer to yours than to Charlotte.
The ask
Pick one item from the action list and get it done before the end of the quarter.
Inside this paper
- Introduction
- The Action at a Glance
- Let’s Start with the Word “Willfully”
- When Capacity Sets the Threshold
- The BSA Officer Seat
- The Lookback Is the Real Bill
- Red Flags Worth Borrowing
- A Preview of AI Exam Questions
- What I’d Do This Quarter
- Where We Go from Here
- Sources
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Coalition Against Financial Crime
An independent professional organization advancing the fight against financial crime through collaboration, practical education, innovation, and action.
cafc.org
An independent professional organization advancing the fight against financial crime through collaboration, practical education, innovation, and action.
cafc.org