Terms Unconditional

Insurance · Insurance/Banking (military-affiliated) · Regulatory action

USAA

Headline

In March 2022 USAA Federal Savings Bank paid $140 million - $80M to FinCEN and $60M to the OCC - for WILLFUL failure to maintain an adequate anti-money-laundering program and to file suspicious activity reports.

In March 2022 USAA Federal Savings Bank paid $140 million - $80M to FinCEN and $60M to the OCC - for WILLFUL failure to maintain an adequate anti-money-laundering program and to file suspicious activity reports. The bank had known about the deficiencies since at least 2017, committed to fixing them by March 2020, then missed that deadline and the extension that followed. FinCEN found that before 2017 the bank's compliance program was 'even more rudimentary due to a lack of financial investment.' Then on December 18, 2024 the OCC issued a new comprehensive cease-and-desist order that replaced BOTH the 2019 and 2022 orders - because USAA had failed to comply with elements of each. Regulators found the failures ran across all three lines of defense at once: the business units, compliance/operations risk, and independent testing - a finding made in FinCEN's 2022 consent order. For an institution whose entire proposition is serving military families, an earlier OCC action (Oct 2020, $85 million civil money penalty) found that the bank's compliance-risk-management failures had led to violations of laws including the Military Lending Act and the Servicemembers Civil Relief Act.

  • SeveritySeverity 5 of 5. In March 2022 USAA Federal Savings Bank paid $140 million - $80M to FinCEN and $60M to the OCC - for WILLFUL failure to maintain an adequate anti-money-laundering program and to file suspicious activity reports.
  • Evidence tierUnassigned
  • Claims confirmed5 of 12 claims confirmed against a primary source
  • Last verified2026-08-04

Primary source. www.fincen.gov/news/news-releases/fincen-announces-140-million-civil-money-penalty-against-usaa-federal-savings — Verified - primary source confirmed.

Last verified 96 days agoverified 96 days ago0180 days
Freshness. Last verified 96 days ago (2026-08-04); stale after 180 days.

Terms

Arbitration

Not independently confirmed this pass — standard binding arbitration + class action waiver expected.

Data sharing

TWO SEPARATE CONFIRMED INCIDENTS: (1) A 2021 breach involving USAA's INSURANCE QUOTE TOOL — a class action alleged the tool's own design (specifically, inadequate access controls) allowed criminals to extract member data, and that USAA failed to take reasonable protective steps; the suit (Dolan v. USAA, S.D.N.Y.) alleged the driver's license numbers of 22,646 consumers were disclosed, and USAA agreed (Dec 2024) to a $3.25 MILLION settlement fund, with an estimated per-claimant payout of approximately $143. (2) A SEPARATE 2024 incident: per Security.org, a configuration error during an update to USAA's document-delivery system posted some member documents to the wrong accounts, affecting a reported 32,276 members.

Fees and billing

Not itemized this pass.

Contacts

Privacy contact. Not recorded.

Legal notice. PUBLIC COMPANY (Non-public). Service route: c/o General Counsel / Corporate Secretary, San Antonio, Texas — the corporate address on the SEC Form 10-K cover page is the official address of record. Confirm the exact street address on the current 10-K at sec.gov/edgar, and check the state-of-incorporation registered agent (usually Delaware; most large filers use The Corporation Trust Company or Corporation Service Company) via the Secretary of State business-entity search. A registered agent MUST accept service, which is why it is the reliable channel when a company publishes no privacy address.

Mailing address. Not recorded.

No published channel
Paper trail: none. No published channel.

Evidence

ClaimKindSupportSources
1. In March 2022 USAA Federal Savings Bank paid $140 million in penalties.factsupportednone recorded
2. $80 million of the penalty went to FinCEN.factunknown1 (1 confirmed)
3. $60 million of the penalty went to the OCC.factunknown1 (1 confirmed)
4. The penalty was for willful failure to maintain an adequate AML program and file suspicious activity reports.factsupportednone recorded
5. The bank had known about the deficiencies since at least 2017.factunsupported1 (1 confirmed)
6. USAA committed to fix the deficiencies by March 2020, then missed that deadline and the extension.factunsupported1 (1 confirmed)
7. USAA's CEO acknowledged the bank had not sufficiently invested in compliance capabilities.factunsupportednone recorded
8. On December 18, 2024 the OCC issued a new comprehensive cease-and-desist order.factunsupported1 (0 confirmed)
9. The 2024 order replaced both the 2019 and 2022 orders because USAA failed to comply with elements of each.factunsupported1 (0 confirmed)
10. Regulators found failures across all three lines of defense.factunsupported1 (1 confirmed)
11. The compliance breakdown contributed to Military Lending Act and SCRA violations.factunsupportednone recorded
12. For an institution serving military families, this breakdown is especially notable.characterizationn/anone recorded

5 of 12 claims have a confirmed source of their own.

Sources

SourceClaimTierStatusQuote
regulator · 2022-03-17
www.fincen.gov/news/news-releases/fincen-announces-140-million-civil-money-penalty-against-usaa-federal-savings
Claim 2Unassignedconfirmed“$80 million representing FinCEN's penalty”
Quote basis: not recorded.
regulator · 2022-03-17
www.fincen.gov/news/news-releases/fincen-announces-140-million-civil-money-penalty-against-usaa-federal-savings
Claim 3Unassignedconfirmed“assessed a civil penalty of $60 million for related violations”
Quote basis: not recorded.
regulator · 2022-03 (F
www.fincen.gov/system/files/enforcement_action/2022-03-18/USAA%20Consent%20Order_Final%20508%20(2).pdf
Claim 5Unassignedconfirmed“Beginning by at least 2017, the OCC informed USAA FSB that there were significant problems with its AML program”
Quote basis: not recorded.
regulator · 2022-03 (F
www.fincen.gov/system/files/enforcement_action/2022-03-18/USAA%20Consent%20Order_Final%20508%20(2).pdf
Claim 6Unassignedconfirmed“missed two completion deadlines over four years and remains out of compliance with them.”
Quote basis: not recorded.
noneClaim 8Unassignednot foundNo quote recorded.
Quote basis: not recorded.
noneClaim 9Unassignednot foundNo quote recorded.
Quote basis: not recorded.
regulator · 2022-03 (F
www.fincen.gov/system/files/enforcement_action/2022-03-18/USAA%20Consent%20Order_Final%20508%20(2).pdf
Claim 10Unassignedconfirmed“first (business unit), second (compliance/operations risk), and third (independent testing) lines of defense.”
Quote basis: not recorded.

Source vault

Link status: Candidate - not yet fetched

DocumentLast fetchPDF
Privacy policy
usaa.com/legal/privacy
Not fetched yetNO (HTML only)
Terms of service
usaa.com/legal/terms-of-use
Not fetched yetNO (HTML only)
Website
usaa.com
Not fetched yet—
Primary source
https://www.fincen.gov/news/news-releases/fincen-announces-140-million-civil-money-penalty-against-usaa-federal-savings
Verification: Verified - primary source confirmed
Not fetched yet—

Enforcement

No enforcement actions are linked to this row.

State statute

Headquarters on file: Texas. Provisions of TDPSA on file:

ProvisionTypeSource
Sensitive Data — Opt-In Consent Required
Tex. Bus. & Com. Code § 541.001(31); § 541.101(b)(4)
hardsource
Applicability — SBA Size-Based, No Numerical Consumer Threshold
Tex. Bus. & Com. Code § 541.002
thresholdsource
Right to Access
Tex. Bus. & Com. Code § 541.051(b)(1)
hardsource
Right to Correction
Tex. Bus. & Com. Code § 541.051(b)(2)
hardsource
Right to Deletion
Tex. Bus. & Com. Code § 541.051(b)(3)
hardsource
Right to Data Portability
Tex. Bus. & Com. Code § 541.051(b)(4)
hardsource
Right to Opt Out of Sale, Targeted Advertising, and Profiling
Tex. Bus. & Com. Code § 541.051(b)(5)
hardsource
Right to Appeal Denied Request
Tex. Bus. & Com. Code § 541.053
hardsource
Privacy Notice Requirements
Tex. Bus. & Com. Code § 541.102(a)
hardsource
Specific Notice Required for Sale of Sensitive Personal Data
Tex. Bus. & Com. Code § 541.102(b)-(c)
hardsource
Processor Contract Requirements
Tex. Bus. & Com. Code § 541.104
hardsource
Enforcement — AG Only; 30-Day Cure; No Private Right of Action
Tex. Bus. & Com. Code §§ 541.151-541.156
hardsource