The Office of the Comptroller of the Currency has fined American Express’s national bank $350 million for failing to catch and report about $13 billion in suspected trade-based money laundering. The penalty, announced October 8, comes with a consent cease-and-desist order against American Express National Bank, which is based in Sandy, Utah. The company agreed to the order, and the money goes to the U.S. Treasury.
The OCC’s release says the activity took place over the past decade and that the bank’s systems for spotting and reporting it broke down. The Federal Reserve announced a separate action against the parent, American Express Company, at 4:30 p.m. Eastern the same day.
For the millions of people who carry an Amex card or keep money in one of its deposit accounts, neither order tells the bank to close accounts, freeze balances or contact customers. Both regulators describe a compliance program that was too weak for the bank’s size, not a loss of customer funds. What changes for account holders, if anything, is likely to show up as more questions about who they are and how they use an account, because customer due diligence is one of the areas the regulators say fell short.
The next step belongs to Amex, which has until early January to give the Federal Reserve Bank of New York its plans for rebuilding the program.
Get the next update the morning it lands →
Five weak spots the OCC lists
The OCC found that the bank did not keep a compliance program reasonably designed to monitor its compliance with the Bank Secrecy Act, the 1970 law that requires banks to keep records and report suspicious activity. It named five specific problems.
- Inadequate resources, including staff without enough expertise
- Systemic gaps in internal controls
- Weak independent testing of the program
- Weak anti-money-laundering training for employees and directors
- Customer due diligence and customer identification procedures that contributed to monitoring and reporting failures
Those gaps added up to what the agency called “systemic breakdowns in its suspicious activity monitoring and reporting processes.” The result, in the OCC’s account, was a failure to identify and report on time the roughly $13 billion in suspected trade-based money laundering.
Comptroller of the Currency Jonathan Gould said the OCC expects banks of American Express’s size and complexity to put enough resources into anti-money-laundering compliance, and that this bank’s program was not “properly aligned” with its money laundering risks.
What “trade-based” laundering means
Trade-based money laundering moves dirty money through the paperwork of commerce. The Treasury’s Financial Crimes Enforcement Network, known as FinCEN, described the basic methods in a 2010 advisory: misstating the price or quantity of imports and exports, and invoicing the same goods or services more than once. Criminal organizations, the advisory says, use the international trade system to transfer value across borders and hide where it came from.
Banks are the checkpoint. They see the payments that settle those invoices, and FinCEN asks them to flag trade-based activity in the narrative of a suspicious activity report. A bank that fails to do so leaves the government without the tip that would let investigators follow the money.
The $13 billion is a measure of suspicion, not a finding of guilt by any customer. The OCC’s wording is “suspected” activity, and nothing in the release says that American Express or its customers have been charged with laundering.
Why a card company’s bank drew the penalty
American Express is known for charge and credit cards, and the bank’s deposit business is much smaller. The OCC said exactly that mismatch was part of the problem. The bank’s own risk assessment focused on its “relatively narrow demand deposit products” and gave too little attention to its larger credit and charge card businesses, so the program was not tailored to where the money actually moved.
The Federal Reserve’s announcement points the same way at the company level. The Board said it acted over the firm’s “failure to sufficiently detect and report certain suspicious activity related to money laundering,” and found “significant deficiencies in how American Express Company’s enterprise-wide anti-money laundering program was implemented,” particularly at the national bank.
The Federal Reserve’s parallel order
The Fed’s consent order, Docket No. 26-052-B-HC, covers American Express Company and its American Express Travel Related Services Company unit. It takes effect October 8 and stays in force until the Reserve Bank stays, modifies, terminates or suspends it in writing. It carries no dollar penalty. Instead it requires written plans on board oversight, the anti-money-laundering program and compliance with sanctions rules enforced by the Treasury’s Office of Foreign Assets Control, all due within 90 days.
The order also bars the company from keeping anyone who took part in the misconduct behind it, and it requires “substantial assistance” to the Board, including interviews and documents. Amex must send the Fed copies of the progress reports it files under the OCC’s order.
Amex’s chief executive, Steve Squeri, said, “While we have made meaningful progress, we know there is more work to do.” The OCC’s release carries the number NR 2026-87.
What account holders can check while Amex rebuilds
The Federal Reserve’s announcement page links the full order and is the free place to read what the company agreed to. The OCC posts its enforcement actions on its own site under the release number above.
Nothing in either order requires action from customers, so the sensible habit is to keep account details current. Banks under a customer due diligence mandate tend to send requests for updated identification, business information or the source of large deposits, and a request that goes unanswered can slow an account. Anyone who gets such a request by mail or email should confirm it through the number on the back of the card or the bank’s own website, since criminals imitate compliance notices.
The order does not say that the plans due to the Reserve Bank will be made public. The surest dated markers are the ones already published: the October 8 effective date and the 90-day filing deadline that follows it, both set out in the Federal Reserve’s order.
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
- 17 Ways Retirees Are Tapping a Record $14.9 Trillion in Home Equity
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.
