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OCC fines American Express $350 million over money laundering compliance failures

The U.S. Office of the Comptroller of the Currency has fined American Express National Bank $350 million over anti-money laundering compliance failures linked to approximately $13 billion in suspected trade-based money laundering activity.

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WASHINGTON, October 8, 2026 — The Office of the Comptroller of the Currency (OCC) issued a cease-and-desist order alongside the civil penalty after finding that the bank failed to maintain an effective Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance program.

The regulator identified significant deficiencies in staffing, internal controls, independent testing and employee training. It found that the bank's risk assessments focused disproportionately on deposit accounts while failing to adequately address money laundering risks associated with its larger credit and charge card operations.

According to the OCC, systemic weaknesses in transaction monitoring and suspicious activity reporting prevented the bank from promptly identifying, evaluating and adequately reporting approximately $13 billion in suspected trade-based money laundering activity over the past decade. The regulator also cited shortcomings in customer due diligence and customer identification procedures that contributed to the bank's monitoring and reporting failures.

Comptroller of the Currency Jonathan Gould said financial institutions must dedicate sufficient resources to anti-money laundering compliance, emphasizing the importance of detecting illicit financial activity to U.S. economic and national security.

The enforcement action was coordinated with a separate cease-and-desist order issued by the Federal Reserve against American Express Co. and American Express Travel Related Services Co. Inc.

The $350 million penalty will be paid to the U.S. Treasury.

The case highlights regulatory concerns over money laundering risks in payment card operations and the importance of aligning transaction monitoring, customer due diligence and risk assessments with financial institutions' actual business activities.

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