On 13 October the US Treasury fined Bank of America more than $1.21 billion, the third-largest penalty in its history. Belarus appears in two places in the documents. The sanctions settlement lists two Belarusian banks among 35 blocked banks whose payments the American bank processed. The money-laundering order describes Belarus as a route for evading export controls, with 290 wires from Belarus in one month to a dealer in damaged cars. In our archive, one Belarusian state outlet reported the case, and it did not mention Belarus; three independent outlets did. What we cannot see is which two banks OFAC means, or how much of the money passed through them.
A small part of a large fine
Most of the money is about money laundering. FinCEN fined the bank $1.2 billion for failing to report suspicious activity, and the bank regulator, the OCC, fined it $750 million, which FinCEN credits against its own penalty. The sanctions part is a separate OFAC settlement of $11,662,930, less than one per cent of the total.
That settlement covers 475 apparent violations between September 2021 and April 2025, across programmes for Russia, Belarus, Iran, Burma, Somalia, drugs and terrorism. From February 2022 to March 2025 the bank processed 403 payments worth $14.3 million that involved 35 blocked banks. Two of them were blocked under the Belarus programme. OFAC does not name them and does not say how much passed through them. The bank disclosed 62 of the violations itself. OFAC called the case non-egregious and still made no reduction to the base penalty.
Salvaged cars
Belarus appears a second time, in the FinCEN consent order. The order names Belarus and Georgia as “intermediary jurisdictions” for evading sanctions and export controls. Its main example is a customer that runs an online marketplace for salvaged vehicles.
Two of them were blocked under the Belarus programme.
In August 2022 alone, the customer’s account received 290 wires from Belarus worth $3.5 million. Bank staff noticed the flow in November 2022, analysed it properly only in March 2023, filed a first suspicious activity report in August 2023, and reported most of the activity only in June 2025. One control the bank considered in 2023 was to stop receiving wires from “sanctioned countries (Russia, Belarus, etc.)”.
Belarusian media rarely tell this part of the car trade. Our archive has about 115 items since 2021 that mention American car auctions together with Belarus. The titles we checked are mostly about buyers: whether it pays to bring a car from America, or a car from the US that turned out to be stolen. Only six items put the auctions in the same passage as resale or transit to Russia, and four of those are from 2022. None of them is from a state outlet after 2022.
In August 2022 alone, the customer’s account received 290 wires from Belarus.
Who reported which part
Our archive holds five items on the fine. The state daily SB published one at 01:47 on 14 October, citing the Russian agency TASS. It gave the $1.21 billion headline, the $750 million and the $11.6 million, and said the sanctions concerned “a number of countries”. SB named the sums, and none of the countries. BelTA did not report the case at all.
Reform worked from the Treasury documents the same afternoon and found both Belarusian lines. Nasha Niva and Svaboda put the two blocked banks in their headlines the next day. A pro-government Telegram channel, Shkvarka, reported only the money-laundering part.
SB named the sums, and none of the countries.
Relief at the top, friction below
The violations end in early 2025. Since then Washington has eased sanctions on Belarus in six rounds tied to prisoner releases, as we set out in September. In March it licensed dealings with Belinvestbank and lifted restrictions on the finance ministry and the Development Bank.
BelTA did not report the case at all.
Relief for named entities does not change how American banks treat wires from Belarus. In August, Zerkalo, republishing devby.io, reported that a High-Tech Park company with an American parent had cut its staff after payments stopped. Its director said problems with transfers to Belarusian banks “have not gone away”. The parent cited US export controls. A penalty with no reduction, for a case the regulator itself calls non-egregious, gives compliance officers little reason to take the risk.
How sure we are
The structure of the fine and both Belarusian lines are High, because they come from the Treasury’s own documents. The coverage count is Medium: five items is a small set, and an item that names Belarus only in a podcast or a video would be missed. The weakest row is the effect on payments today, which rests on one company’s account.
How it fits
How it fits. The only state outlet that covered the fine reported its sums in detail and left out both places where Belarus appears, while the Treasury’s own release names Belarus in its list of sanctions programmes. This fits T4, incidents come with a media plan, including silence: here the silence covers the Belarusian line inside a story the state press did run. A simpler reading is that SB copied TASS, and TASS may not have named the countries either, so the omission was inherited rather than chosen. We could not find the TASS text. If a future OFAC action names Belarus in a wire that SB carries, and SB keeps the line, the inherited reading wins. If the line disappears again, the silence is SB’s own.
What to watch
By 31 March 2027, OFAC publishes another enforcement action that names the Belarus sanctions programme. We expect it does not, with Medium confidence.
By 31 December 2026, a Belarusian state outlet mentions the two blocked Belarusian banks in the Bank of America case. We expect it does not, with High confidence.
By 30 June 2027, OFAC removes a second Belarusian bank from the SDN list or licenses dealings with it, after Belinvestbank. We expect it does, with Medium confidence.
Method and limits
The amounts, periods and counts come from the OFAC enforcement release, the FinCEN consent order and the OCC release of 13 October 2026. We searched our archive from 10 October for every item naming Bank of America, by segment, and flagged whether each named Belarus, OFAC or money laundering. For the car trade we searched from 2021 for items naming American car auctions together with Belarus, and counted those that mention resale or transit to Russia within about 120 characters. That search is loose and catches some unrelated items, so we use the total only as an order of magnitude. We searched for earlier OFAC penalties linked to Belarusian banks since 2022 and found none in our archive, though a case reported only in English trade press could be missed. We did not see the TASS item that SB cites. Thesis tag: T4.