Enforcement Release: October 13, 2026
Bank of America, N.A. Settles with OFAC for $11,662,930 Related to Apparent Violations of Multiple Sanctions Programs
Bank of America, N.A. (Bank of America), a national banking association headquartered in Charlotte, North Carolina, has agreed to pay $11,662,930 to settle its potential civil liability for 475 apparent violations of OFAC sanctions programs targeting Russia, Belarus, Iran, Burma, Somalia, narcotics, and global terrorism. The apparent violations occurred when Bank of America processed payments involving blocked banks, failed to appropriately prioritize alerts for customers who were exact name- and date of birth-matches to blocked persons, failed to promptly update watchlists following OFAC designations, and mishandled two business accounts associated with blocked persons due to human error. The settlement amount reflects OFAC’s determination that Bank of America’s apparent violations were non-egregious but largely not voluntarily self-disclosed. This settlement amount also reflects no...
1) From a legal basis of violations standpoint, this is a straightforward enforcement action, though some of the factual scenarios are unique to this case. This is particularly so with respect to the “routing directory” that resulted in payments being made to and through blocked Russian banks. Note that some of the violations involved “payments…processed shortly after the relevant bank was blocked by OFAC and before Bank of America updated its sanctions screening filter to reflect the bank’s blocked status,” illustrating OFAC’s expectation that SDN listing actions be incorporated immediately into compliance functions (especially at banks). Based on what is disclosed in the enforcement actions, it appears that OFAC was particularly unhappy with the fact that “despite telling OFAC in more than one instance that it was investigating payments it had processed involving blocked banks, Bank of America initially performed only...