FinCEN, the OCC and OFAC penalize Bank of America by almost $2 billion, and OFAC hits the financial network of Mexico's Cartel del Noreste. What banks, remittance companies and fintechs in Latin America should review today.
Between October 11 and 15, the U.S. Department of the Treasury sent two clear messages to any institution with U.S. dollar exposure: monitoring failures are very expensive, and Mexican organized crime keeps using seemingly legitimate businesses to move money. Here is what matters and what to review.
1. KYC/AML: a record penalty for Bank of America
On October 13, FinCEN assessed a $1.2 billion penalty against Bank of America, N.A., the third largest in Treasury history according to the official release. The bank admitted that it willfully violated the Bank Secrecy Act: it failed to maintain an AML program meeting minimum requirements, failed to conduct the required due diligence on correspondent accounts for foreign financial institutions, and failed to timely report more than $5 billion in suspicious transactions. Over $1 billion of that amount was tied to national security priorities, such as Chinese money laundering networks, fraud and potential trade-based money laundering along the southwest border.
On the same day, the OCC imposed a $750 million civil money penalty, the largest in its history, for a deficient BSA/AML program. OFAC also reached an $11.66 million settlement covering 475 apparent violations of its Russia, Belarus, Iran, Burma, Somalia, narcotics and terrorism programs. According to OFAC, the causes were correspondent payments involving blocked banks, poorly prioritized alerts on exact name and date of birth matches, and delayed watchlist updates.
Treasury describes a familiar pattern: alerts left uninvestigated for long periods, reliance on external requests instead of the bank's own monitoring, and unexplained payments from unknown third parties. The FATF published no updates during the period.
2. GAFILAT
No official updates since our October 8 edition.
3. Dominican Republic
The Superintendency of Banks issued no new rules after its October 6 circular letter, and the Financial Analysis Unit (UAF) and the securities regulator (SIMV) published no AML announcements in these days. For those with U.S. dollar correspondent relationships, the Bank of America case signals tougher reviews by their correspondents.
4. Latin America: Mexico and Venezuela on OFAC's lists
On October 13, OFAC designated 4 individuals and 11 Mexican entities linked to the Cartel del Noreste (CDN) under its narcotics program and, in 13 of the 15 cases, also as Specially Designated Global Terrorists (SDGT). The network includes a racetrack on the outskirts of Nuevo Laredo, a Quarter Horse racing stable in Nuevo Leon, construction companies with public contracts, gas distributors and a freight company. OFAC said it coordinated the action with Mexico's Financial Intelligence Unit.
On October 14, OFAC removed from the SDN List, under the Venezuela program, the entries for Jorge Jesus Rodriguez Gomez. The notice does not state the reason; update your lists to avoid false positives.
Practical takeaways for regulated companies
- Measure your alert backlog: set maximum review times and escalate overdue alerts.
- Do not rely on third parties: your reports should come from your own monitoring.
- Review correspondent banking: update due diligence on your foreign banks.
- Calibrate screening: prioritize exact name and date of birth matches and load changes the same day.
- Look beyond the financial sector: in racetracks, construction, fuel and logistics in northern Mexico, identify the ultimate beneficial owner.
At Global KYC & Compliance Solutions, we automate screening and monitoring so your team can close alerts on time and react the same day the lists change.
Sources
- FinCEN – $1.2 billion penalty against Bank of America (Oct 13, 2026)
- U.S. Treasury – Enforcement actions against Bank of America (Oct 13, 2026)
- OFAC – Settlement with Bank of America, N.A. (Oct 13, 2026)
- U.S. Treasury – Sanctions on the Cartel del Noreste network (Oct 13, 2026)
- OFAC – Counter narcotics and counter terrorism designations (Oct 13, 2026)
- OFAC – Venezuela-related designation removal (Oct 14, 2026)
- Dominican Republic Superintendency of Banks – Regulations (Oct 2026)