# OFAC Penalizes Bank of America for Screening Failures

OFAC settled with Bank of America for **$11,662,930** over 475 apparent sanctions violations involving failures in payment screening, match prioritization, watchlist updates, and handling accounts connected to blocked persons. OFAC provided no penalty reduction for the bank’s remediation or cooperation. For government contractors and other organizations handling payments or third-party transactions, the case highlights the financial and operational exposure created by ineffective sanctions-screening controls and poorly managed lookbacks or disclosures.

- Organizations handling cross-border payments should test screening controls and third-party data feeds, and ensure potential exact matches are investigated promptly.
- Contractors should maintain documented, appropriately scoped lookbacks and self-disclosure processes; the settlement indicates remediation and cooperation may not result in penalty mitigation.
- Procurement teams can use the case when assessing sanctions-related controls in payment workflows and third-party relationships.

**Jurisdictions:** federal
**Topics:** Regulatory Compliance
**Published:** October 25, 2026

### Government Entities
- Office of Foreign Assets Control (OFAC)
- U.S. Department of the Treasury (Treasury)

### Sources
- [Episode 462 -- 475 Sanctions Violations: Screening, Cooperation, and the Cost of Getting No Credit | The Volkov Law Group - JDSupra](https://www.jdsupra.com/legalnews/episode-462-475-sanctions-violations-99447) - JD Supra