Federal regulators announced a combined set of enforcement actions against Bank of America on Oct. 13. The Office of the Comptroller of the Currency assessed a $750 million civil penalty against the bank for deficiencies in its anti-money-laundering program, including failures related to suspicious activity reports and wire information. FinCEN separately assessed a $1.2 billion penalty, which credits the OCC’s $750 million assessment, for failures to mitigate and report specified national-security risks. The actions concern the bank’s compliance systems and reporting obligations, not an assertion that its customers as a group engaged in wrongdoing. The two amounts therefore should not be added as though they were separate, fully cumulative penalties. The coordinated actions address compliance obligations at the same institution.