OCC fines American Express National Bank $350 million over anti-money laundering failures

The Office of the Comptroller of the Currency fined American Express National Bank $350 million on October 8 and issued a cease-and-desist order over deficiencies in its Bank Secrecy Act and anti-money laundering compliance program, according to the regulator’s release. The Federal Reserve Board issued a separate cease-and-desist order the same day against American Express Company and its American Express Travel Related Services subsidiary, PYMNTS reported.

The OCC said the program at the Sandy, Utah-based bank suffered from inadequate resources, including staff without sufficient expertise, systemic internal control gaps, weak independent testing and weak training for employees and directors, according to FinTech Futures. The regulator also found that the bank oriented its risk framework too heavily toward deposit account products, leaving its larger credit and charge card operations without adequate scrutiny, according to Yahoo Finance. Comptroller of the Currency Jonathan Gould said the bank failed to maintain a program aligned with the money laundering risks of its operations, which led it to miss significant suspicious activity and to fail to report it and to give law enforcement important information.

The OCC found that about $13 billion in suspected trade-based money laundering activity went inadequately identified, evaluated and reported over roughly a decade, according to American Bazaar Online’s summary of the order. Michael Padula, a former Justice Department money laundering prosecutor, told Banking Dive that the bigger question was “how $13 billion went inadequately reported for so long.”

Under the Fed order, American Express must submit a plan to improve its enterprise-wide compliance risk management program, Banking Dive reported. The Fed described the deficiencies as enterprise-wide but particularly acute at the national bank subsidiary. The company, which has about $308 billion in assets, did not admit or deny the findings, according to Crowdfund Insider.

American Express chairman and chief executive Stephen Squeri said a portion of the penalty was reserved in earlier periods and that it does not affect the company’s full-year 2026 guidance, according to Yahoo Finance. The consent orders do not impose an asset cap, and the costs of meeting their requirements are not expected to affect 2027 guidance, the company said in a statement quoted by Doctor of Credit. It is the OCC’s first civil money penalty against a bank since a $450 million penalty against TD Bank in October 2024, according to Banking Dive.

American Express reported second-quarter earnings of $4.53 per share on July 24 and raised its full-year revenue growth guidance to 10 percent.