Lawsuit claims Bank of America buried $5B in suspicious transactions

A new class action lawsuit accuses Bank of America of hiding massive anti-money laundering failures from investors.

The complaint, filed November 12, 2026 in US District Court in New York, alleges the banking giant repeatedly assured shareholders it had "adopted appropriate risk management and compliance programs" while its compliance systems were, according to the filing, deeply broken.

At the heart of the case is a December 23, 2024 consent order from the Office of the Comptroller of the Currency - the federal regulator that oversees national banks. That order found Bank of America's banking subsidiary had failed to maintain reasonably effective anti-money laundering and sanctions compliance programs, the complaint says. The OCC flagged problems with internal controls, testing, training, and oversight, according to the filing.

The company kept reassuring investors, the complaint alleges. In its 2024 annual report, Bank of America stated it had "already completed significant steps to satisfy requirements of the Consent Order" and did not "believe that these issues relating to the Programs will have a material adverse financial impact on the Corporation," the filing says.

That reassurance unraveled on October 13, 2026. After markets closed, the US Department of the Treasury announced enforcement actions imposing more than $1.21 billion in penalties against Bank of America for "violations of anti-money laundering and sanctions laws," according to the complaint.

The filing alleges the bank's subsidiary admitted it "willfully violated" federal anti-money laundering law. Its monitoring failures caused it to miss reporting "over $5 billion dollars in suspicious transactions" to the Financial Crimes Enforcement Network, the complaint says - including "over $1 billion" tied to "national security-related and other priority illicit finance risks."

Even after agreeing to the 2024 consent order, the bank "still failed to prioritize" its compliance obligations, the complaint alleges, citing the OCC. The subsidiary "did not complete many of the significant steps needed to establish an effective" compliance program "and its program continues to have significant breakdowns," according to the filing.

The complaint describes a compliance function that was systematically deprioritized. The filing alleges the company "prioritized its revenues and minimized the impact on its required compliance resources." Rather than relying on its own monitoring systems, the subsidiary leaned on "law enforcement inquiries, requests by other financial institutions, and similar interventions" to flag suspicious activity - effectively "outsourcing to third parties a substantial portion of its proactive detection and reporting obligations," the complaint says.

The scale of the alleged failures is stark. The OCC found the bank's monitoring deficiencies caused it to "fail to properly monitor trillions of dollars in transactions," resulting in "large numbers of late" suspicious activity reports "involving billions of dollars," according to the filing. The complaint further alleges the OCC determined the company "knew for years that it was failing to escalate potentially suspicious activity to investigators" but "failed to correct this serious" violation.

Bank of America disclosed the next morning that the $1.2 billion settlement charge had cut diluted earnings per share by $0.17, the complaint states.

Analysts reacted sharply. The complaint cites a J.P. Morgan report titled "BSA/AML Consent Orders Include Surprising Comments From Regulators," which described the action as "much more punitive because regulators concluded that BofA had not made sufficient progress." The analysts called the cited deficiencies "quite extensive" and described the "lack of oversight by the Board on this matter" as "also surprising," the filing says.

Bank of America's stock dropped $2.57 per share - approximately 4.7% - to close at $51.39 on October 14, 2026, according to the complaint. Its preferred depositary shares fell $0.11, or roughly 0.72%, to $15.21 per share that same day.

The lawsuit brings claims under federal securities law, covering investors who purchased Bank of America common stock or its Series QQ preferred depositary shares between January 20, 2022 and October 13, 2026. The complaint states that the company's alleged misconduct took place from at least January 1, 2018 through July 1, 2025.

The allegations have not been tested, and no court has ruled on the claims.