USAA Federal Savings Bank was assessed a combined $140 million civil money penalty by FinCEN and OCC in March 2022 for willfully failing to implement and maintain an effective AML program and for failing to accurately and timely file thousands of suspicious activity reports and currency transaction reports from at least January 2016 through April 2021.

USAA Federal Savings Bank — BSA/AML Willful Violations, $140 Million Penalty (2022)

Outcome: USAA Federal Savings Bank admitted to willfully failing to implement and maintain a BSA-compliant AML program from January 2016 through April 2021 and was assessed a combined $140 million civil money penalty by FinCEN ($80 million) and the OCC ($60 million) in March 2022.

USAA Federal Savings Bank, headquartered in San Antonio, Texas, is a federally chartered savings bank serving U.S. military members and their families. Despite operating with this specialized, relatively lower-risk customer base, USAA FSB allowed its BSA/AML compliance infrastructure to deteriorate severely while its banking business grew. FinCEN's investigation found that the bank's BSA/AML compliance department was significantly understaffed and that management relied heavily on third-party contractors to fill gaps — an arrangement that proved inadequate to maintain compliant monitoring and reporting.

The willful violations spanned a period of at least five years, from January 2016 through April 2021. USAA FSB admitted that it willfully failed to implement and maintain an AML program that met BSA minimum requirements, willfully failed to accurately and timely report thousands of suspicious transactions to FinCEN, and negligently failed to file thousands of Currency Transaction Reports. The suspicious activity that went unreported included customers using personal accounts for apparent criminal activity across multiple categories.

The regulatory history reveals an institution that knew about its compliance failures and repeatedly failed to fix them. USAA FSB authored internal "2018 Commitments" pledging specific improvements to its BSA/AML program, yet missed two completion deadlines over four years and remained out of compliance at the time of the penalty assessment in 2022. Management at the bank had knowledge of the ongoing violations throughout this period.

The combined $140 million penalty — $80 million to FinCEN and $60 million to the OCC — represented one of the largest BSA-related bank penalties in U.S. history at the time of issuance. USAA FSB paid $290 million to the U.S. Treasury as part of the FinCEN settlement (having previously paid $100 million to the OCC in 2018 for similar violations, which was credited against the total).

Primary Source: FinCEN Press Release — $140 Million Civil Money Penalty Against USAA Federal Savings Bank