BAC · CIK 70858
What Bank of America Corporation told the SEC could break it.
For a bank of its scale, the disclosures here lean overwhelmingly toward regulatory and geopolitical exposure rather than any single business concentration. The macro channel comes through U.S.–China tensions and tariff escalation, which could disrupt financial markets and invite retaliation — counter-tariffs, FX measures, or large-scale selling of U.S. Treasuries — feeding into its market-making and derivatives portfolios. The rest is the compliance burden of operating globally: extensive OFAC sanctions, Bank Secrecy Act anti-money-laundering and anti-corruption obligations, and resolution-planning demands from regulators across the UK, France, Mexico, Hong Kong, and Southeast Asia. It also flags model risk, including from its growing reliance on AI applications.
4 self-disclosed vulnerabilities, pulled from its own filings, each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Regulatory & policy
- U.S.-China tensions / tariff escalation affecting financial markets and trademedium
Escalating U.S.-China tensions, including tariff increases, could trigger further U.S. measures that disrupt financial markets, world trade and commerce, and lead to trade retaliation (counter-tariffs, FX measures, large-scale sale of U.S. Treasuries) — adversely affecting BofA's businesses, clients, and market-making/derivatives portfolios.
“the continuation or escalation of tensions between the U.S. and the People's Republic of China (China), including tariff increases, could lead to further U.S. measures that adversely affect financial markets, disrupt world trade and commerce and lead to trade retaliation, including through the use of counter tariffs, foreign exchange measures or the large-scale sale of U.S. Treasury bonds.”
- OFAC sanctions, BSA/AML, FCPA and UK Bribery Act compliancemedium
BofA is subject to extensive sanctions (OFAC), anti-money-laundering (Bank Secrecy Act), know-your-customer, and anti-corruption (FCPA, UK Bribery Act) requirements across the U.S. and other jurisdictions, with significant compliance and penalty exposure.
“we are subject to the U.S. Bank Secrecy Act (BSA), which contains anti-money laundering and financial transparency laws designed to detect and deter money laundering and the financing of terrorism, as well as record-keeping, reporting, due diligence and customer verification”
Other disclosures
- model risk — including AI-reliant applicationslow
BofA's models — increasingly including AI-reliant applications — are inherently limited by simplifying assumptions and may not be predictive during extreme/unanticipated market movements or stress events, creating model risk in decision-making and risk management.
“models are inherently limited by simplifying assumptions, uncertainty in economic and financial outcomes, and emerging risks, including from applications that rely on AI. Our models may not be sufficiently predictive of future results, including from limited historical patterns, extreme or unanticipated market movements”
SEC filing →As of 2026
The hidden graph
Who it depends on, and who depends on it.
Relationships surfaced from filings, including ones disclosed by the other side, which is how the non-obvious ones come to light.
Its customers
Helix Energy Solutions Group, Inc.
“provides for potential ESG-related pricing adjustments based on specific metrics and performance targets determined by us and Bank of America, as agent with respect to the Amended ABL Facility.”
Cited →
Its suppliers
“As of December 31, 2025, only Bank of America (4.3%) and Asurion (3.5%) accounted for more than 3% of our annualized GAAP revenues.”
Cited →
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