OCC: OCC Assesses $350 Million Civil Money Penalty Against American Express

• OCC found American Express failed to timely report approximately $13 billion of suspected trade-based money laundering activity over the past decade.
• OCC issued a cease-and-desist order in coordination with a concurrent action by the Board of Governors of the Federal Reserve System on October 8, 2026.

The Office of the Comptroller of the Currency (OCC) issued a cease-and-desist order and imposed a $350 million civil money penalty against American Express National Bank for deficiencies in its BSA/AML compliance program. The OCC determined the bank failed to establish and maintain a program reasonably designed to assure and monitor compliance with the Bank Secrecy Act and its implementing regulations.

The OCC found systemic breakdowns in American Express's suspicious activity monitoring and reporting processes, including failures to timely identify, evaluate, and sufficiently report approximately $13 billion of suspected trade-based money laundering activity over the past decade. The OCC's actions were coordinated with a concurrent cease-and-desist order by the Board of Governors of the Federal Reserve System.

• $350 million civil money penalty assessed
• $13 billion suspected trade-based money laundering activity

• Review the OCC's Consent Order (PDF) for specific BSA/AML program requirements imposed on American Express National Bank.
• Assess exposure to trade-based money laundering typologies, referencing the $13 billion of suspected activity cited by the OCC.
• Verify compliance with the Board of Governors of the Federal Reserve System's concurrent cease-and-desist order against American Express Company and American Express Travel Related Services Company, Inc.

This enforcement action highlights the critical importance of aligning BSA/AML compliance programs with the actual money laundering risks posed by a bank's business activities. The OCC's findings underscore that inadequate risk assessments, insufficient resources, and weak internal controls can result in significant failures to detect and report suspicious activity, as evidenced by the $13 billion in missed trade-based money laundering. Compliance officers must ensure robust monitoring, reporting, and due diligence processes to avoid regulatory penalties and support law enforcement efforts.