The Federal Reserve has placed American Express under a consent order over weaknesses in how the company detects and reports suspicious activity tied to money laundering. The Fed’s order carries no dollar penalty. The money in this case comes from a separate action by another regulator.
The Fed announced the order on October 8. It names American Express Company and its subsidiary American Express Travel Related Services, known as TRS, and it took effect the same day.
What the Federal Reserve found
The Fed says it identified significant deficiencies in how American Express carried out its company-wide anti-money-laundering program, particularly at its national bank subsidiary. In its announcement, the Board says the firm failed to sufficiently detect and report certain suspicious activity related to money laundering. The release carries no quotes from officials and does not discuss customers.
The details are in the order itself, a consent cease-and-desist order filed as Docket No. 26-052-B-HC. Consent means American Express agreed to its terms.
The 90-day clock
The order sets a schedule. Within 90 days of October 8, which falls on January 6, 2027, the American Express board must submit a written plan to the Federal Reserve Bank for board oversight of the company’s compliance. A second plan must cover the company’s Bank Secrecy Act and anti-money-laundering risk management, and TRS must file a plan for compliance with sanctions rules enforced by the Treasury Department’s Office of Foreign Assets Control.
After that, the order calls for progress reports every quarter, due within 45 days after the end of the first full calendar quarter following the order. It also bars American Express and TRS from retaining certain individuals in the future, and it stays in force until the Reserve Bank stays, modifies, terminates or suspends it in writing.
People who hold an American Express card will want to know if the order changes their account. Nothing in the Fed’s release or the order text announces new fees, card changes or any step for cardholders. The requirements fall on the company: plans, oversight and reporting.
The number to watch in this case is the quarterly progress report American Express must now file with the Fed, starting after the first full calendar quarter that follows the October 8 order.
Get each new number in one short weekday email →
The OCC’s separate $350 million penalty
The Fed’s order is half of a two-agency action. The release says the Office of the Comptroller of the Currency, the national bank regulator known as the OCC, issued its own enforcement action against American Express’s national bank. Banking Dive reports that the OCC’s action pairs a cease-and-desist order with a $350 million civil money penalty against American Express National Bank, for anti-money-laundering failures between June 2014 and May 2025. The trade publication also reports that about $13 billion in suspected trade-based money laundering went undetected in that period.
Trade-based money laundering moves illicit money through the buying, selling and shipping of goods, so the payments look like ordinary business. Banking Dive reports that the OCC cited systemic breakdowns in how the bank monitored and reported suspicious activity, and that the bank must submit an action plan within 90 days and carry out a look-back at past activity.
The Fed’s own order sets the same 90-day timing for its plans. The Fed’s release says only that the OCC’s action is separate and does not give a penalty figure for it.
What American Express says
Banking Dive quotes American Express chief executive Stephen Squeri as saying: “While we have made meaningful progress, we know there is more work to do.” The report says the company does not expect the actions to affect its full-year 2026 or 2027 guidance, because the amounts were reserved in earlier periods.
A company that tells investors an expense was already reserved is saying the cost has been absorbed in its books. It is not saying the compliance work is finished. The Fed order’s quarterly reports and the OCC look-back are where that work will show up.
What the plans must cover
The order spells out the contents. The board plan must hold senior management accountable for fixing the problems under both the Fed order and the OCC order, give management enough resources, and set up reporting and escalation to the board. The anti-money-laundering plan must cover written policies, transaction monitoring with tested rules and thresholds, customer due diligence matched to risk, and a suspicious activity reporting program across every line of business. It must also cover oversight of network partners, ATM partners and other third parties. The sanctions plan for TRS must include a method for assessing risk, job-specific training and screening procedures.
The company may not keep anyone who took part in the misconduct, was disciplined for it after the company’s internal review, and then left. Each plan needs a timeline, and the company must adopt an approved plan within 10 days of approval by the Federal Reserve Bank of New York. Progress reports must include copies of the reports required under the OCC order. The order sets no dividend restriction.
Where to check a bank’s enforcement history
The Federal Reserve keeps a public enforcement actions database. It lists orders against banks and holding companies, including this one, with the order text attached. The search is free and does not require an account.
Cardholders who want to check their own exposure can do the same things that applied last week. Read the monthly statement, dispute any charge that is not recognized, and use the number on the back of the card to reach the issuer. Nothing in the Fed’s announcement changes those steps.
The two dates to keep in mind are January 6, 2027, when the first plans are due at the Federal Reserve Bank, and the end of the first full calendar quarter after the order, which starts the 45-day clock for the first progress report. The Fed has not said whether it will publish the plans or the reports.
More Financial Reading
- 24 Ways to Stretch a $2,087 Social Security Check
- 17 Places to Find Your Share of the $4.25 Billion States Give Back
- The New $6,000 Senior Deduction and 15 More Tax Moves for Retirees
This article was produced with AI assistance and reviewed by The Financial Wire’s editorial team.
Warren Cohen is a finance writer based in Phoenix, Arizona, covering personal finance topics including credit, banking, and beginner investing. He earned his degree in business administration from Arizona State University and began his career working in consumer finance, where he gained direct experience with lending and credit systems. He now writes for personal finance websites and fintech platforms, focusing on clear, practical content that helps readers make informed financial decisions.
