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The OCC imposed a $350 million civil money penalty and a cease-and-desist order on American Express National Bank over anti-money laundering program failures. The Federal Reserve separately issued cease-and-desist orders to American Express and its travel-related services arm, requiring plans to strengthen compliance.
The Office of the Comptroller of the Currency ordered American Express National Bank to pay a $350 million civil money penalty and issued a cease-and-desist order over anti-money laundering failures, while the Federal Reserve issued separate orders to American Express and its travel-related services arm. The actions require the company and its bank subsidiary to address deficiencies in programs intended to detect and prevent financial crime.
The OCC said the bank, based in Sandy, Utah, did not adequately tailor its Bank Secrecy Act and anti-money laundering risk assessment to its business. According to the agency, the assessment focused too heavily on the bank’s “relatively narrow” demand deposit products and did not give enough attention to the risks associated with its more dominant credit and charge card products.
The regulator also cited what it described as “systemic breakdowns” in suspicious activity monitoring and reporting. The OCC said those breakdowns resulted in roughly $13 billion in suspected trade-based money laundering activity between June 2014 and May 2025. That figure refers to suspected activity identified by the agency; the source material does not establish that the full amount was confirmed laundering.
The Fed described the problems in the AML program at the $308 billion-asset company as “enterprise wide,” while saying they were particularly pronounced at the national bank subsidiary. Its order requires American Express to submit a plan to improve enterprise-wide BSA/AML compliance risk management. The travel-related services arm, or TRS, must submit a separate plan addressing compliance with the Office of Foreign Assets Control.
Compliance Orders Reach Across Amex
The actions put both the bank and broader corporate operations under regulatory directions, rather than addressing only one isolated process. The bank must improve how it identifies risks across its products, monitors transactions and reports suspicious activity. The Fed’s separate requirements extend the response to enterprise-wide AML risk management and TRS’s OFAC compliance.
The $350 million penalty is also notable in the OCC’s recent enforcement record. Banking Dive, citing OCC data, reported that it was the agency’s first civil money penalty against a bank since its $450 million penalty against TD in October 2024. That comparison describes enforcement timing, not the relative scale of the underlying conduct: TD’s penalty formed part of more than $3.5 billion in total penalties and was accompanied by a $434 billion asset cap on its U.S. retail banking operations.
For customers and other readers, the orders matter because AML controls are meant to help financial institutions spot and report transactions that may involve money laundering or other financial crime. The regulators’ findings identify weaknesses in those controls at a large card issuer and its bank subsidiary. They do not, on the information provided, establish that individual customers’ accounts or transactions were involved in wrongdoing.
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How Regulators Described the Gaps
The Bank Secrecy Act requires financial institutions to maintain systems for detecting and reporting suspicious activity. In this case, the OCC’s findings focused on whether the bank’s risk assessment reflected its actual mix of products and whether its monitoring and reporting systems functioned effectively. The agency said the bank’s emphasis on deposit accounts did not adequately reflect the greater role of its credit and charge card business.
The enforcement actions were issued concurrently by two federal regulators, with the OCC acting against American Express National Bank and the Fed issuing orders involving American Express and TRS. The OCC’s order sets out requirements for the bank, including a third-party review looking back at suspicious activity. These supervisory directions are intended to require remedial work; the provided report does not say the regulators have found that all deficiencies have already been corrected.
American Express Chief Executive Officer Stephen Squeri said the company had worked with regulators and law enforcement while strengthening controls. He also said a portion of the penalty had been reserved for in prior periods. According to Squeri, the penalty does not affect the company’s full-year 2026 guidance, and the consent orders are not expected to affect its 2027 guidance.
“American Express takes its responsibility to combat financial crimes seriously.”
— Stephen Squeri, American Express chief executive officer
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Scope of Remediation Still Developing
The source report describes the story as developing. The available information does not specify the full terms of every remedial requirement, the detailed contents of the plans the regulators expect, or whether the agencies will impose further action after reviewing them. It also does not establish that the roughly $13 billion in suspected activity represents confirmed money laundering or state how much, if any, was ultimately tied to proven criminal conduct.
The source does not provide a completion date for the required third-party review or the full timetable for the Fed’s plans. Squeri said the penalty would not affect 2026 guidance and the orders were not expected to affect 2027 guidance, but those statements reflect the company’s assessment. The materials provided do not include independent financial analysis of that outlook.
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Plans and Reviews Due to Regulators
American Express National Bank must create an action plan within 90 days to address the OCC’s cited compliance deficiencies. The OCC order also requires the bank to develop an effective BSA/AML risk assessment process and a consumer due diligence and risk-identification program, and to hire a third party for a suspicious activity look-back review.
American Express must submit its enterprise-wide BSA/AML compliance risk management plan to the Fed, while TRS must provide its plan addressing OFAC compliance. The next key developments will be the regulators’ review of those submissions and the progress of the bank’s required remediation and third-party review. The source material gives no specific deadline for the Fed submissions or date for a further regulatory update.
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Key Questions
Which American Express entity was fined?
The OCC fined American Express National Bank $350 million and issued it a cease-and-desist order. The Federal Reserve issued separate cease-and-desist orders to American Express and its travel-related services arm.
What failures did the OCC cite?
The OCC said the bank’s risk assessment did not adequately reflect its credit and charge card business and cited systemic breakdowns in suspicious activity monitoring and reporting.
Does the $13 billion figure mean that amount was confirmed as laundered?
No. The OCC described roughly $13 billion as suspected trade-based money laundering activity between June 2014 and May 2025. The available report does not say that the full amount was confirmed as laundering.
What must the bank do next?
Within 90 days, American Express National Bank must create an action plan to address the OCC’s concerns. It must also improve its risk assessment and customer due diligence processes and arrange a third-party review of suspicious activity.
Will the orders affect American Express’s financial guidance?
CEO Stephen Squeri said the penalty would not affect the company’s full-year 2026 guidance and that the orders were not expected to affect its 2027 guidance. Those are statements by the company; the source material does not provide an independent assessment.
Source: rss
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