On Tuesday July 11th, 2023, both the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) announced fines of $6 million against Merrill Lynch Pierce, Fenner & Smith and its parent company BAC North America Holding Co (BACNAH) . These fines are the result of the broker-dealer failing to file 1,500 required suspicious activity reports (SARs) over the years of 2009 to 2019 following the merger between Merrill Lynch and Bank of America in 2009. During the transition, BACNAH, who assumed responsibility for implementing Merrill Lynch’s SAR policies and procedures and filing their SARs, incorrectly applied a $25,000 threshold for reporting suspicious activity instead of the required $5,000 threshold applicable to broker-dealers. A number of suspicious activities went unreported, including forged or altered checks, identity theft, and internet scams amongst others. In settling this matter, Merrill Lynch will pay $6 million to the SEC and $6 million to FINRA.