In this episode of Corruption, Crime and Compliance, Michael Volkov examines OFAC’s $11,662,930 settlement with Bank of America for 475 apparent sanctions violations, together with what the full Treasury package shows about remediation and cooperation. He walks through four failure modes: payments through 35 blocked banks, exact name and date of birth matches ranked as low priority, stale watchlists caused by vendor and internal errors, and mishandled business accounts tied to blocked persons. Volkov explains why OFAC gave no penalty reduction for remediation or cooperation, pointing to a narrow initial lookback, piecemeal responses, reckless conduct, and prior cautionary letters, and he outlines what the bank must now do under the FinCEN, OCC, and OFAC resolutions. He closes with eight practical lessons, including prioritizing exact matches, verifying daily watchlist updates, reviewing auto-clear rules, scoping lookbacks to root causes, building a self-disclosure process in advance, and integrating AML and sanctions programs.