OFAC fines Bank of America $11 million for 475 sanctions violations across multiple programs

WASHINGTON, D.C., Oct. 13, 2026 — The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) announced that Bank of America, N.A., has agreed to pay $11.66 million to settle potential civil liability for 475 apparent violations of sanctions targeting Russia, Belarus, Iran, Myanmar, Somalia, narcotics trafficking and global terrorism.

The violations occurred between September 2021 and April 2025 and involved approximately $14.83 million in transactions. OFAC attributed the failures to deficiencies in payment screening, delayed sanctions watchlist updates, weaknesses in alert prioritization and human errors involving accounts associated with blocked individuals.

The largest category of violations involved 403 transactions totaling $14.34 million routed through 35 sanctioned banks, including 32 Russian banks, two Belarusian banks and one Iranian bank. OFAC found that Bank of America continued processing certain payments involving blocked institutions despite identifying weaknesses in its payment-routing systems in March 2022.

Further violations resulted from deficiencies in the bank's sanctions screening systems. A design flaw caused alerts involving customers whose names and dates of birth exactly matched sanctioned individuals to be assigned lower priorities, allowing three designated individuals to conduct 31 transactions totaling $56,258 before the issue was fully corrected in February 2024.

Separately, delays in updating sanctions watchlists resulted in 32 transactions worth approximately $247,371 involving designated entities. These failures included third-party vendor delays in 2023 and technical problems affecting sanctions screening in February 2025.

OFAC also identified failures involving business accounts linked to blocked individuals. In one incident, bank employees transferred $189,869 from restricted accounts into an unrestricted account before compliance personnel identified the error and blocked the funds.

The agency classified the violations as non-egregious but determined that 413 were not voluntarily self-disclosed, while 62 were self-disclosed. OFAC cited reckless conduct, inadequate compliance controls, previous warnings concerning similar violations and insufficient cooperation during its investigation.

The $11.66 million settlement reflects no reduction from the base penalty, with OFAC declining to apply mitigation for the bank's remedial measures or cooperation.

The settlement was announced alongside broader Treasury enforcement actions against Bank of America involving more than $1.21 billion in penalties for sanctions and anti-money laundering compliance failures. These included a $1.2 billion penalty imposed by the Financial Crimes Enforcement Network and a separate $750 million penalty assessed by the Office of the Comptroller of the Currency.

The enforcement action highlights OFAC's expectations that financial institutions maintain effective sanctions screening systems, promptly implement designation updates, oversee third-party providers and adequately investigate and disclose potential compliance failures.