q100 · askamerica

How much more likely are small banks to face enforcement action than large ones, once you account for how many there are?

Answer

Once you divide enforcement actions by the number of banks in each size tier, the naive "small banks bear the brunt" story inverts: a bank with $1B+ in assets was about 2.6x more likely than a sub-$1B bank to draw a BSA/AML enforcement action in 2024.

Raw counts: 54% of the 39 bank-directed BSA/AML enforcement actions issued by federal regulators in 2024 went to institutions under $1 billion in assets (Crowe analysis of 2024 regulator data).

But small banks vastly outnumber large ones. Live FDIC BankFind institution counts (fetched 2026-08-24): - 4,244 active FDIC-insured institutions total - 3,197 (75.3%) under $1B in assets - 1,040 (24.5%) at or above $1B - 155 (3.65%) at or above $10B

Rate per institution: - Sub-$1B banks: ~21 actions / 3,197 banks ≈ 0.66% - $1B+ banks: ~18 actions / 1,040 banks ≈ 1.73% - Ratio (large ÷ small) ≈ 2.6x

Caveat — this is a directional proxy, not a comprehensive census. No public API combines all enforcement actions (all agencies, all violation types, all years) with a size breakdown — FDIC's BankFind API has institutions/financials/history/locations/failures/summary/demographics endpoints but no enforcement endpoint, and OCC/Federal Reserve enforcement orders are only individually browsable, not bulk-downloadable. This answer uses the best size-stratified sample found (2024 BSA/AML actions, n=39) against a live, exact FDIC population count. A different, smaller sample (13 fintech-related actions from 2023) shows the opposite pattern — all 13 went to banks under $10B, none to $10B+ banks — demonstrating the small-vs-large gap is category-dependent, not one fixed multiplier. The data gap was logged to AskAmerica's issue tracker (report_issue).

Full report

Published via the AskAmerica connector's publish_report: http://127.0.0.1:51237/a/40511cb82cac93487c1bc4ccddc17ab4.html (local-only link; see saved images below for the visuals).

Sources

FDIC BankFind Suite API — institutions endpoint, live query, https://api.fdic.gov/banks/institutions (fetched 2026-08-24)
Crowe, "Enforcement Action Trends: Insights for 2025", https://www.crowe.com/insights/fincrime-in-context/enforcement-action-trends-insights-for-2025
Goodwin, "Bank Enforcement Actions Shape Financial Policy Landscape", https://www.goodwinlaw.com/en/insights/publications/2024/08/alerts-finance-ftec-supervisory-experience-and-enforcement-actions
FDIC BankFind Suite API endpoint documentation, https://api.fdic.gov/banks/docs

Files in this directory

chart-population-vs-enforcement-share.png — bar chart: population share vs. 2024 BSA/AML enforcement-action share, by size tier
dashboard.png — stat-tile dashboard (0.66% / 1.73% / ~2.6x) inlined in the published report