American Express Bank Fined $350 Million Over Anti-Money Laundering Failures
Key Facts
The U.S. Office of the Comptroller of the Currency imposed a $350 million civil penalty on American Express National Bank, alongside an enforcement action announced by the Federal Reserve on October 8, 2026. The OCC said transaction monitoring and reporting deficiencies covered about $13 billion in suspected trade-based money laundering activity. The OCC also issued a cease-and-desist order to address deficiencies in the bank's compliance with anti-money laundering requirements. The Federal Reserve attributed its action to failures to detect and report certain suspicious activities at the group. According to the OCC, proceeds from the penalty imposed on the bank will go to the U.S. Treasury.
The OCC order identified the period covered by the suspicious activity as approximately June 2014 to approximately May 2025. Some cases addressed in the order involved accounts linked to bank insiders, according to its supervisory findings. In its risk assessment, the OCC said the bank placed excessive emphasis on deposits when identifying the risks facing its business. The assessment, meanwhile, paid insufficient attention to credit card and charge card products, despite their dominance in the bank's business. The deficiencies described by the OCC thus extended to how supervisory attention was allocated across the bank's products, including those accounting for the bulk of its activity.
The OCC attributed the deficiencies to insufficient compliance resources, alongside problems with the expertise of staff working in the area. The OCC described part of the problem as involving "staff lacking sufficient experience," among the reasons it cited for the program's shortcomings. It also identified weaknesses in independent testing of the compliance program, one of the findings addressed in its actions against the bank. At the group level, the Federal Reserve order identified weaknesses in transaction monitoring as part of its review of controls related to combating financial crime. Its findings also covered fraud indicator referrals and third-party risk assessments, with the regulatory actions addressing multiple aspects of monitoring and compliance at American Express.
American Express said in a filing with the U.S. Securities and Exchange Commission that the orders resolve previously disclosed regulatory reviews. Those reviews concerned the group's financial crime compliance program, according to the company's description of the background to the settlement and the actions covered by the filing. The bank consented to the OCC order without admitting or denying its supervisory findings, according to the order. The Federal Reserve order acknowledged that the company and its travel services subsidiary had "fully cooperated" with regulators in the review. The Fed also noted that both entities had begun taking corrective action ahead of completing the remediation requirements imposed on them by the order.
On the financial impact, American Express said part of the penalty had been reserved for in prior periods, according to its regulatory filing. The company affirmed that the penalty does not change its previously announced full-year 2026 outlook, in explaining the financial impact of the regulatory actions on its business. It added that the consent orders "do not impose an asset cap," according to the filing outlining its position on the restrictions accompanying those orders. Regarding implementation requirements, the company also addressed the costs of complying with the orders when discussing its guidance for the following year, alongside its position on the penalty. It said it expects the costs of implementing those requirements to have no impact on its 2027 guidance, an estimate the company attributed to the impact of the required remediation work.
In the next phase, the OCC order requires the bank to engage an independent third-party consultant to review past suspicious activity reporting. The consultant's remit includes identifying missing reports as well as reports requiring correction, as part of the requirements to review the bank's reporting history. The Federal Reserve order gives the company and its travel services subsidiary 90 days from its effective date to submit the required oversight and compliance plans. These plans include the travel services subsidiary's compliance with sanctions administered by the U.S. Office of Foreign Assets Control, according to the requirements in the order. Progress reports must also be submitted within 45 days after the end of the first full calendar quarter following the order, and after each subsequent quarter for as long as it remains in effect.