OFAC Announces $11,662,930 Settlement with Bank of America, N.A.
OFAC · 1 source
What's on the official record
13 October 2026 — settlement agreement. The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced an $11,662,930 settlement with Bank of America, N.A. Bank of America agreed 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 page cites no Executive Order for this action. 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 the apparent violations were non-egregious but largely not voluntarily self-disclosed. Record: https://ofac.treasury.gov/recent-actions/20261013_33.
Assessment
For a sanctions or trade-finance committee, the record names four screening and alert-handling controls to check against the committee's own program: whether payments involving blocked banks are processed, whether alerts for exact name- and date of birth-matches to blocked persons are prioritized, whether watchlists are updated promptly after OFAC designations, and whether accounts associated with blocked persons are handled without human error. OFAC's determination that the apparent violations were non-egregious but largely not voluntarily self-disclosed gives the committee a benchmark for its own self-disclosure posture. That frames a decision to hold a payment flow or enhance diligence on the named controls.
For an owner or operating executive, the record supplies a pre-diligence checklist of the four control gaps OFAC named in the settlement: processing payments involving blocked banks, prioritizing exact name- and date of birth-match alerts, refreshing watchlists promptly after designations, and handling accounts tied to blocked persons without human error. The record characterizes the apparent violations as non-egregious but largely not voluntarily self-disclosed. An executive can use that finding to fix the named controls before a buyer or lender checks, or to delay an external review until they are corrected.
What would change this call
A revised settlement amount or violation count from OFAC would change the benchmark in this note. An OFAC Enforcement Release or the settlement agreement naming an Executive Order or statute would change the note's statement of the legal basis. A recharacterization by OFAC of the violations as egregious or voluntarily self-disclosed would change the assessment.
What to check next
| Check | Why it matters |
|---|---|
| OFAC corrected or amended settlement amount or violation count | Benchmarks the 475 apparent violations and $11,662,930 figure |
| OFAC statement naming an Executive Order or statute for this settlement | The page currently cites no Executive Order for this action |
| OFAC statement recharacterizing the violations as egregious or voluntarily self-disclosed | The page states non-egregious but largely not voluntarily self-disclosed |
Confidence
Filed 23 October 2026 from the record dated 13 October 2026. This note is drawn from the single OFAC recent-actions page; no Executive Order or statute is cited on that page, and the note reports only what the page states.
Sources
[1] OFAC Recent Actions, "Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and Bank of America, N.A.", 13 October 2026, https://ofac.treasury.gov/recent-actions/20261013_33.