Financial Sector’s Need for Enhanced Crime Risk Education Post Bank of America Fine

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October 21, 2026
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Bank of America recently faced a $1.2 billion fine for its involvement in money laundering and sanctions evasion. This serves as a critical lesson for the financial sector. The fine’s significance lies not in its hefty amount, but in the underlying issues that led to it. Two prominent weaknesses at Bank of America included failing to identify and report over a billion dollars in suspicious activities related to national security and the static nature of 76 percent of its risk factor weights over a five-year period. Many weights that did change were reduced by about 80 percent.

This presents a clear disconnect between financial crime prevention and the geopolitical context in which these crimes occur. Financial institutions often treat money laundering and sanctions evasion as mere compliance tasks. This routine approach misses the main reasons for sanctions and the associated national security risks. Recognizing that not all financial crimes bear the same weight is crucial. For example, someone evading sanctions to aid North Korea’s nuclear efforts poses a greater threat than a local drug dealer.

The Iran War strategy focuses on economic warfare, with significant emphasis on hindering Iran’s sanctions evasion and money laundering. American foreign policy sees Iranian sanctions evasion as a strategic priority. Bank of America’s unchanged risk factor weights during a period of major geopolitical shifts, such as Russia’s invasion of Ukraine in 2022, highlights institutional complacency. The bank kept risk weights static even as Russian sanctions evasion networks evolved, showing a lack of adaptation to global risks.

Regulators noted insufficient recalibration of risk factors despite internal evidence of shortcomings. To adapt to evolving financial crime risks, banks need professionals with geopolitical insights. The private sector requires a complete overhaul of financial crime education. Insufficient expertise and training consistently rank as major concerns in the financial sector. In recent reports, a growing number of professionals see geopolitical instability as a high-risk factor.

The need to tailor anti-financial crime programs to reflect changes in national security and foreign policy is pressing. Organizations must enhance their training beyond compliance checklists to truly equip staff with necessary skills. Leaders with insights into these dynamics are pivotal to transforming static systems into adaptable frameworks. The industry needs not only operational training but also an in-depth understanding of financial crime impact on American safety.

Ultimately, this isn’t only about checking regulatory boxes. Financial crime education must include awareness of broader illicit finance contexts. Without adequately trained staff, companies cannot effectively counter the evolving threats. Brett Erickson, managing principal at Obsidian Risk Advisors and advisory board member at Seton Hall School of Diplomacy and International Relations, emphasizes the sector’s need for rigorous, continuous training in this critical area.