What Bank of America Corporation told the SEC could break it.

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.”

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”

Foreign regulators (including the UK, France, Mexico, Hong Kong, Indonesia, the Philippines and Malaysia) require submission of significant information on locally incorporated subsidiaries and branches for resolution planning, which could force costly actions over the next several years.

“France, Mexico, Hong Kong, Indonesia, the Philippines and Malaysia where rules have been issued requiring the submission of significant information about locally incorporated subsidiaries as well as the Corporation's banking branches located in those jurisdictions that are deemed to be material for resolution planning purposes.”

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”