OCC and Federal Reserve Fine American Express $350 Million Over Decade of AML Failures
OCC and Federal Reserve Fine American Express $350 Million Over Decade of AML Failures #
American Express National Bank has been fined $350 million by the Office of the Comptroller of the Currency and issued a cease-and-desist order after regulators found persistent failures in the firm’s anti-money laundering program. The Federal Reserve Board issued coordinated enforcement actions the same day against American Express Company and its travel-related services subsidiary.
The OCC and the Fed acted concurrently on Thursday, October 8, after identifying what regulators described as “significant deficiencies” in American Express’s enterprise-wide Bank Secrecy Act and AML compliance framework. The OCC cited inadequate compliance staffing, a failure to tailor the firm’s BSA/AML risk assessment to its actual business activities, weak independent testing, insufficient staff training, and systemic breakdowns in suspicious activity monitoring and reporting.
From approximately June 2014 to May 2025, a span of roughly a decade, the bank processed around $13 billion in suspected trade-based money laundering activity, including transactions linked to bank insiders, according to the OCC. The regulator also found that suspicious activity reporting was untimely, incomplete, or missed altogether across both the trade-based money laundering activity and other suspected illicit transactions.
“The OCC expects banks of American Express’s size and complexity to devote sufficient resources to ensure compliance with laws and regulations designed to detect and prevent money laundering, which are critical to both economic and national security,” Comptroller of the Currency Jonathan Gould said in the OCC’s press release.
As part of its remediation requirements, the OCC is mandating that American Express National Bank establish a board-level compliance committee and submit a comprehensive remediation plan. The agency is also requiring an independent look-back review to determine whether additional suspicious activity reports should have been filed, with results to be provided to the examiner-in-charge. The Fed’s order, directed at the parent company and its travel services arm, requires those entities to submit their own remediation plans addressing financial-crime control deficiencies across the broader enterprise.
American Express Chairman and CEO Stephen Squeri acknowledged the actions in a statement, saying the company takes its responsibilities around fighting financial crime seriously and is committed to addressing the regulators’ concerns. The company noted in an SEC filing that a portion of the $350 million penalty had already been reserved in prior periods and that the fine is not expected to alter its full-year 2026 guidance. Compliance costs related to the consent orders are also not anticipated to affect 2027 guidance. The OCC did not impose an asset cap, a measure that would have constrained the bank’s growth, as part of the enforcement action.
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