When software does the compliance job: lessons from the Bank of America OFAC settlement

Wed, 21 Oct 2026 00:00:00 +0000

On October 13, OFAC announced an $11,662,930 settlement with Bank of America, N.A. for 475 apparent sanctions violations between September 2021 and April 2025.

The OFAC release is the one I’d send to anyone outside banking. Nearly every violation traces back to screening software that was set up wrong or was fed stale data, then trusted without anyone checking. If you run restricted-party screening for export controls, a DLP rule that keeps CUI out of personal email, an automated marking rule, or a workflow that routes license determinations, you’ve entrusted software with a regulatory duty. The regulator will hold you responsible for what it does.

Export Controls on Dan Kiehl

When software does the compliance job: lessons from the Bank of America OFAC settlement