OCC Fines American Express National Bank $350 Million Over Anti-Money Laundering Failures

Federal regulators hit American Express with a $350 million civil penalty on Thursday, Oct. 8, over anti-money laundering failures that the Office of the Comptroller of the Currency says stretched across roughly a decade.

The OCC fined American Express National Bank. The Federal Reserve separately issued its own cease-and-desist action covering American Express Co. and American Express Travel Related Services.

What the OCC found

The OCC said the bank "experienced systemic breakdowns in its suspicious activity monitoring and reporting processes." The result, per the agency, was a failure to timely identify, evaluate and sufficiently report approximately $13 billion of suspected trade-based money laundering.

The order covers activity from about June 2014 to about May 2025. It describes a mix of suspicious card charges and the repayments of those charges.

In certain instances, the OCC said, the activity ran through accounts associated with bank insiders. The order does not name those individuals or spell out their roles.

The agency also found that suspicious activity reports were untimely, missed or incomplete. Its criticisms reach the bank's know-your-customer processes, staffing, expertise, employee training and internal audits.

According to the OCC, the bank's risk assessments focused too heavily on its relatively small deposit-taking business. They gave too little weight to the far larger credit and charge card operations that drive its revenue.

Comptroller of the Currency Jonathan Gould said the failures deprived law enforcement of important information about potentially illicit financial flows.

The Fed's separate order

The Fed's action is broader in reach. It cites assessments by the Federal Reserve Bank of New York that found "significant deficiencies in Amex's enterprisewide financial crimes risk management program." The listed weaknesses are transaction monitoring, fraud referral processes, third-party risk assessment and financial crimes risk management.

The OCC order requires a board-level compliance committee and a comprehensive remediation plan. It also requires an independent review of historical transactions to determine whether more suspicious activity reports should have been filed. The findings go to the bank's examiner-in-charge.

Amex's response

Chairman and CEO Stephen Squeri said the company "takes its responsibility to combat financial crimes seriously" and is "fully committed to addressing the concerns outlined by the FRB and OCC."

Squeri said Amex has worked closely with regulators over the past few years while strengthening its controls. He said the company has made "substantial investments in our people, technology, training, governance, and oversight."

He also said Amex investigated transactions processed over its network by individuals misusing its products to buy goods and services. The company reported that information to law enforcement and took other action, he said. "While we have made meaningful progress, we know there is more work to do," Squeri said.

In a regulatory filing, Amex said the orders do not impose an asset cap. It said the penalty will not affect its previously issued 2026 guidance. It said costs tied to the fixes are not expected to affect 2027 guidance either. The company has said a portion of the penalty was already reserved.

Amex shares fell nearly 2% to $302.10 in after-hours trading at 5:22 p.m. ET Thursday. That is an after-market price, not a regular-session move.

The regulatory backdrop

The penalty arrives while federal bank watchdogs have been easing rules on large lenders. They have relaxed how much capital banks must hold against losses, narrowed the scope of bank supervision and shrunk a Federal Reserve unit dedicated to bank oversight. Bloomberg described the Amex fine as one of the steepest imposed by financial authorities in President Donald Trump's second term.

The actions announced Thursday are civil. No criminal charges against the company or any individual have been announced.

The $13 billion over eleven years is a large figure. It is also described by the OCC as suspected activity, not adjudicated crime. The order's wording on insiders is narrow: accounts "associated with" bank insiders, with no names and no stated roles.

What comes next

The independent look-back is the piece to watch. If reviewers find transactions that should have produced suspicious activity reports, the bank will have to file them. That could give law enforcement information regulators say it never received.

Whether the look-back sheds light on the insider-linked accounts is an open question. Neither regulator has said.