Grabar Law Office Investigates Claims on Behalf of Shareholders of Bank of America Corporation (NYSE: BAC) Following More Than $1.21 Billion in Federal Penalties for Anti-Money Laundering and Sanctions Compliance Violations

Grabar Law Office is investigating claims on behalf of shareholders of Bank of America Corporation (NYSE: BAC) concerning possible breaches of fiduciary duties by certain current and former officers and directors arising from the Company's alleged longstanding failures to maintain adequate anti-money laundering ("AML") controls, comply with the Bank Secrecy Act ("BSA"), and adhere to federal economic sanctions requirements.

Why? On October 13, 2026, the U.S. Department of the Treasury announced enforcement actions imposing more than $1.21 billion in penalties against Bank of America for violations of federal anti-money laundering and sanctions laws. The enforcement actions included:

• A $1.2 billion civil penalty assessed by the Financial Crimes Enforcement Network ("FinCEN") for violations of the Bank Secrecy Act;
• A $750 million civil penalty imposed by the Office of the Comptroller of the Currency ("OCC"), credited toward the FinCEN penalty; and
• An approximately $11.66 million settlement with the Office of Foreign Assets Control ("OFAC") involving 475 apparent violations of U.S. sanctions programs.

According to Treasury, these enforcement actions included the third-largest penalty in Treasury history and the largest civil monetary penalty ever imposed by the OCC.

Significantly, Bank of America admitted material facts and violations as set forth in the FinCEN Consent Order, including that it willfully violated the Bank Secrecy Act by failing to implement and maintain an adequate AML program, conduct required due diligence concerning foreign correspondent accounts, and file required suspicious activity reports.

FinCEN's investigation identified misconduct extending from at least January 1, 2018 through July 1, 2025. According to the Consent Order, deficiencies in Bank of America's transaction-monitoring system resulted in the missed or delayed detection and reporting of more than $5 billion in suspicious activity, including approximately $1 billion implicating national security and other priority illicit-finance risks.

Treasury further reported that Bank of America had been aware for years of serious deficiencies in its transaction-monitoring systems but failed to take adequate corrective action. These deficiencies allegedly persisted despite repeated internal warnings, regulatory scrutiny, and a December 2024 OCC cease-and-desist order requiring improvements to the Bank's compliance program.

The separate OFAC enforcement action identified 475 apparent sanctions violations occurring between September 2021 and April 2025, involving payments processed through blocked financial institutions, deficient sanctions screening, delayed watchlist updates, and other compliance failures.

Grabar Law Office is investigating whether Bank of America's directors and officers failed to exercise appropriate oversight of the Company's regulatory compliance, internal controls, and risk-management systems, potentially exposing the Company to substantial financial penalties, remediation expenses, and reputational harm.

If you have continuously held Bank of America Corporation (NYSE: BAC) common stock since before January 1, 2018, you are encouraged to contact Joshua H. Grabar at jgrabar@grabarlaw.com, or call 267-507-6085, to discuss your rights and the possibility of participating in this shareholder derivative investigation.  You can seek corporate reforms, the return of funds spent defending litigation back to the company, and a court approved incentive award, at no cost to you whatsoever.