OCC orders AmEx to pay $350M over AML deficiencies

American Express National Bank will pay a $350 million civil money penalty after the Office of the Comptroller of the Currency found significant deficiencies in the bank's Bank Secrecy Act and anti-money laundering compliance program.

The OCC announced the penalty Oct. 8 along with a cease-and-desist order. The Federal Reserve issued a related enforcement action against American Express Co. and American Express Travel Related Services Co. the same day.

According to the OCC, American Express National Bank failed to maintain a BSA/AML program reasonably designed to monitor compliance with federal requirements. The regulator cited inadequate resources, staff without sufficient expertise, systemic internal-control gaps, weak independent testing and insufficient training for employees and directors.

The OCC also found the bank's risk assessments were not adequately tailored to its business. The bank focused heavily on risks tied to its relatively narrow demand-deposit products while giving insufficient attention to its much larger credit and charge card operations.

Card activity drew insufficient scrutiny

The deficiencies extended to customer due diligence, customer identification and suspicious-activity monitoring, the OCC said. Those weaknesses contributed to failures to timely identify, evaluate and sufficiently report about $13 billion in suspected trade-based money laundering activity over the past decade.

Comptroller of the Currency Jonathan Gould said institutions of American Express's size and complexity are expected to devote sufficient resources to detecting and preventing money laundering.

"American Express failed to maintain a BSA/AML compliance program properly aligned with the money laundering risks of its operations," Gould said. He added that the deficiencies led to missed suspicious activity and reduced the amount of useful information available to law enforcement.

Reuters reported that the regulatory findings included understaffing, insufficiently trained personnel and broad weaknesses in internal controls. American Express did not admit wrongdoing as part of the action.

AmEx says remediation is underway

American Express Chairman and CEO Stephen Squeri said the company had already identified areas for improvement through internal and external reviews and had been working with regulators and law enforcement.

"We are fully committed to addressing the concerns outlined by the FRB and OCC and continuing to strengthen our Financial Crimes Compliance program," Squeri said.

The company said it has increased investment in personnel, technology, training, governance and oversight and has improved monitoring and investigative capabilities. It also said the $350 million penalty will not affect its full-year 2026 guidance and that the consent orders do not impose an asset cap.

The OCC's order requires American Express National Bank to strengthen its BSA/AML compliance program, including customer due diligence, suspicious-activity monitoring, internal controls, testing and training.

The Federal Reserve's related action also requires improvements to compliance and risk-management practices across American Express entities. The company said remediation efforts are already underway and that it is continuing to work with regulators.

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