American Express has until January 6, 2027, to hand the Federal Reserve three written plans for fixing its anti-money-laundering controls. The deadline comes from a consent order the Fed Board issued October 8, and it runs 90 days from that effective date. Each plan goes to the Federal Reserve Bank of New York.
The order is the Fed’s half of a coordinated enforcement action. On the same day the Comptroller of the Currency fined American Express National Bank $350 million and ordered it to fix its own program. The Fed’s order covers the parent, American Express Company, and its American Express Travel Related Services Company unit, known in the document as TRS.
Cardholders and account holders are not asked to do anything. The order addresses customers only through the company’s required customer due diligence program and its sanctions screening procedures. For the people those programs touch, the order is a promise of tighter checks on who is opening and using accounts, with a regulator reading the plans before they are adopted.
Once the January filings land, Reserve Bank approval starts a 10-day clock to adopt each plan, and the first quarterly progress report follows in mid-May.
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Three plans, three owners
The order, Docket No. 26-052-B-HC, assigns each plan to a different party, and the opening words of each paragraph set the same clock: “Within 90 days of the effective date of this Order.”
The first plan belongs to the Amex Board of Directors. It must cover how the board will hold senior management accountable for remediation, make sure management has enough resources, make sure the company runs an effective enterprise-wide program under the Bank Secrecy Act and anti-money-laundering rules, and receive proper reporting and escalation of problems.
The second plan belongs to the company. It is the compliance risk management plan, and it must cover six things: written policies, standards and procedures; transaction monitoring methods; a customer due diligence program; a suspicious activity reporting program; oversight of the compliance systems, including those run by network partners, ATM partners and other third parties; and escalation of material money laundering and sanctions risks.
The third plan belongs to TRS and deals with the Treasury Department’s Office of Foreign Assets Control, which administers U.S. sanctions. It must include a risk assessment method, periodic training and stronger policies, including screening procedures.
A regulator approves before anything is adopted
Submitting a plan does not finish the job. Each plan must include a timeline with specific completion deadlines, and Amex and TRS must adopt it within 10 days of approval by the Reserve Bank. Once adopted, a plan cannot be amended without the Reserve Bank’s approval for as long as the order lasts.
That term has no fixed end date. The order stays in force until the Reserve Bank stays, modifies, terminates or suspends it in writing. The Reserve Bank may also grant written extensions of time at its sole discretion, so the January 6 date is a starting deadline and not a guaranteed final one.
Reports every quarter until the Fed is satisfied
The Amex Board, or a committee it authorizes, must send written progress reports to the Reserve Bank. The first is due within 45 days after the end of the first full calendar quarter following the order. Because the order took effect October 8, in the middle of the fourth quarter, the first full quarter is January through March 2027, which puts the first report in mid-May. Reports continue each quarter after that.
Each report must include copies of the progress reports Amex files under the OCC’s order, which ties the two agencies’ oversight together. Amex does not get to tell one regulator a different story from the one it tells the other.
People tied to the misconduct cannot stay
One paragraph of the order reaches individuals. Amex and TRS may not in the future directly or indirectly keep anyone who participated in the misconduct underlying the order and who was disciplined and then separated or terminated. A separate paragraph requires “substantial assistance” to the Board’s work, including interviews, testimony and documents.
The Fed’s announcement frames the action around the company’s “failure to sufficiently detect and report certain suspicious activity related to money laundering.” The Board says it found significant deficiencies in how the enterprise-wide program was implemented, particularly at the national bank. The order itself says the Board investigated the firm’s failure to detect such activity on time and enough.
The document is signed for the company by Bernadette Miragliotta, managing counsel for litigation and investigations, and for the Board by Associate Secretary Michele Taylor Fennell. Unlike the OCC’s action, it carries no dollar penalty.
Following the January 6 filing date
The free source for the whole timeline is the Federal Reserve’s own enforcement announcement for October 8, which links the order as an attachment. Reading the order itself takes a few minutes, and its first pages list every plan and every element, so anyone who wants to know what the company agreed to can read it in full.
Three dates are worth writing down. January 6, 2027, is when the three plans are due. Ten days after the Reserve Bank approves each one, it must be adopted. The first progress report lands about mid-May 2027, after the quarter that ends March 31. The order does not say whether the plans or reports will be released publicly, so the visible signals may be limited to later announcements from the regulators or the company.
For account holders, the main thing to watch is the due diligence program. If Amex begins asking for updated identification or more information about how an account is used, that request is a likely result of the work this order demands. Confirm any such request through the phone number on the back of the card or the company’s own website before replying.
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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.
