Full Breakdown
American Express National Bank Fined $350 Million for AML Deficiencies
By Drooid · · How we work
Enforcement Action Overview
On October 8, the Office of the Comptroller of the Currency (OCC) and the Federal Reserve announced a coordinated enforcement action against American Express National Bank. Regulators imposed a $350 million civil penalty and issued a cease-and-desist order after determining that the bank’s anti-money-laundering (AML) program was insufficient. The agencies said the lender failed to identify, evaluate, and report roughly $13 billion in suspicious activity over the past decade, citing inadequate resources, inexperienced staff, weak training, and internal-control gaps. The action also requires an independent look-back review and the creation of a board-level compliance committee to oversee remediation.
Background & Context
The Bank Secrecy Act obligates U.S. banks to maintain robust protocols for flagging suspicious transactions and filing suspicious activity reports (SARs). Prior supervisory assessments by the Federal Reserve Bank of New York highlighted significant weaknesses in American Express’s enterprise-wide financial-crimes risk management, including transaction monitoring, fraud referral processes, and third-party risk assessment. Regulators found that the bank focused on risks in its narrow deposit products while neglecting its much larger credit-card business, leading to systemic breakdowns in monitoring and reporting.
Data & Statistics
- Penalty: $350 million civil fine.
- Suspicious activity: Approximately $13 billion processed from 2014 to 2025, encompassing trade-based money laundering and transactions involving bank insiders.
- Compliance gaps: Inadequate staffing, insufficient training, weak internal controls, and deficient customer-due-diligence and identification programs.
Official Statements & Responses
- Jonathan Gould, Comptroller of the Currency: Stated that the OCC expects banks of American Express’s size and complexity to devote sufficient resources to AML compliance, emphasizing its critical role for economic and national security.
- Federal Reserve: Described “significant deficiencies” in the bank’s financial-crimes risk management program, noting weaknesses in transaction monitoring, fraud referral, and third-party risk assessment.
- Stephen J. Squeri, Chairman and CEO of American Express: Asserted that the bank is “fully committed” to addressing regulator concerns, that the penalty and remediation costs are not expected to affect 2027 guidance, and that the firm has made substantial investments to strengthen its AML controls.
Verbatim Quotes
- “The OCC expects banks of American Express's size and complexity to devote sufficient resources to ensure compliance with laws and regulations designed to detect and prevent money laundering, which are critical to both economic and national security,” — Comptroller
- “We have made and continue to make substantial investments in our people, technology, training, governance, and oversight to fortify how we identify, assess, and respond to evolving financial crimes risk across our business and the industry.” — Stephen J. Squeri, chairman and CEO
What’s Next
- The OCC ordered an independent look-back to determine whether additional SARs should have been filed; the findings will be submitted to the examiner-in-charge.
- The Federal Reserve requires American Express’s parent companies to submit detailed remediation plans covering transaction monitoring, fraud referral, and third-party risk management.
- American Express must establish a board-level compliance committee and develop a comprehensive remediation plan to bring its AML program into alignment with regulatory expectations.