Fed: Federal Reserve Board announces enforcement action against American Express Company to address, among other things, the firm’s failure to sufficiently detect and report certain suspicious activity related to money laundering

• Federal Reserve Board identified significant deficiencies in American Express Company's enterprise-wide anti-money laundering program, especially at its subsidiary national bank (Federal Reserve Board, October 08, 2026).
• The Office of the Comptroller of the Currency issued a separate enforcement action against American Express Company's national bank (Federal Reserve Board, October 08, 2026).

On October 08, 2026, the Federal Reserve Board announced an enforcement action against American Express Company due to its failure to sufficiently detect and report certain suspicious activity related to money laundering. The action aims to address compliance gaps and strengthen the firm's AML controls.

The Board also found significant deficiencies in the implementation of American Express Company's enterprise-wide anti-money laundering program, particularly at its subsidiary national bank. The Office of the Comptroller of the Currency issued a separate enforcement action against the bank to address these issues.

• Review American Express Company's enterprise-wide anti-money laundering program for deficiencies identified by the Federal Reserve Board.
• Assess suspicious activity detection and reporting processes at American Express Company's subsidiary national bank as referenced in the enforcement action.
• Monitor the separate enforcement action issued by the Office of the Comptroller of the Currency against American Express Company's national bank.

This enforcement action highlights the importance of robust AML/CFT controls and the need for financial institutions to effectively detect and report suspicious activity. Compliance officers must ensure their programs meet regulatory expectations, especially in light of identified deficiencies at American Express Company and its subsidiary national bank. The involvement of both the Federal Reserve Board and the Office of the Comptroller of the Currency underscores heightened regulatory scrutiny and the potential for multiple enforcement actions when AML failures occur.