“The bank's BSA Officer and staff lacked sufficient skills and expertise to effectively manage the bank's BSA/AML program."

That's extraordinary language from a federal regulator.

> Bank of America admits that it willfully violated

That’s a stunning admission to see from a corporate settlement with anyone, much less the government. And: they were fined $2B of revenue for processing $5B of money, which is far beyond the usual degree of punitive for a U.S. corporation admitting to greed. Wow. I wonder what we’re not hearing about that they settled rather than admit publicly.

so BoA made $12B and has to pay a 10% fine? bummer, that ...

> with over $1 billion of this activity implicating national security-related and other priority illicit finance risks

periodic reminder that 9/11 only cost around $200,000 to pull off

the pretext for these laws and the penalties behind them are completely undermined by decades of billion dollar non-compliant money movements

all of that money is clean now and in the system earning interest. If terror and organized crime was intended to be caught at these transaction moments, at $10bn cleared that means 50,000 9/11 scale attacks are possible with domesticated clean money that would never be caught in this dragnet on everyone else. That's before decades of interest or investment into this economy.

I think the bank’s lackadaisical view of this is an accurate and rational response. Even the best compliance to the bank secrecy act is undermined by simply using someone else’s social security number or employer identities number to make the account.

> Chinese Money Laundering Networks and illicit finance along the southwest border.

You'd think after TDs 3 billy they'd go higher. Probably hurt their own investments too much?

Some more discussion: https://news.ycombinator.com/item?id=50080613