OCC Imposes $750 Million Assessment Against Bank of America for Deficient BSA/AML Compliance

When anti-money laundering controls fail at scale, the root cause is almost always an undocumented risk tolerance decision—someone approved customer onboarding thresholds, monitoring parameters, and alert tuning without producing a durable record of who decided, why, and what review cadence applied. The BSA Officer's quarterly certification becomes ceremonial when the underlying risk assessments and system configuration approvals exist only in email or slide decks, not as engineered decision artifacts with apex linkage to board oversight. This enforcement action demonstrates that compliance programs built on narrative and attestation rather than structured decision records cannot prove adequacy when the regulator arrives. Every decision, on the record.