The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against BAO for $1.2bn.
The enforcement action against Bank of America (with OCC, FinCEN, OFAC, and others) was for BOA’s failing to maintain an effective Bank Secrecy Act/AML program, including flawed transaction monitoring that led to inadequate suspicious activity reporting, weak customer due diligence, and deficient sanctions screening, sometimes with law enforcement flagging issues to the bank rather than the reverse.
They place this alongside recent actions against UBS, American Express, and a New York DFS fine of SEB, arguing recurring failures stem from poor transaction analysis. Kelly ties Bank of America’s problems to its homegrown “Event Processor” system launched in 2010, criticized for arbitrary risk-scoring thresholds and lack of recalibration, compounded by insufficient staffing and management support. They highlight governance and accountability concerns, including unresolved prior findings from a 2024 OCC order, questions about board compliance oversight, and doubts that fines alone will drive lasting remediation.
Key Highlights
- BofA Fine Breakdown
- What Went Wrong in AML
- How the Tech Failed
- Leadership and Culture Accountability
- Fixing It People and Oversight
- Risk Assessments and Too Big to Remediate
Resources
Matt in Radical Compliance
Tom in the FCPA Compliance Report
Tom
A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.