OCC Fines American Express Bank $350 Million

The Office of the Comptroller of the Currency imposed a $350 million civil penalty on American Express National Bank and ordered it to strengthen anti-money-laundering controls, while the Federal Reserve separately ordered American Express parent entities to address financial-crime deficiencies. The OCC announced its enforcement action on October 8. It said the bank processed approximately $13 billion in suspected trade-based money-laundering activity from about June 2014 to May 2025. The figure includes suspicious card charges and associated repayments, according to the regulator; it is an estimate of suspected activity, not a finding that the entire amount represented criminal proceeds. The OCC said shortcomings in the bank’s monitoring and reporting systems led to suspicious-activity reports that were untimely, missed or incomplete. Its findings also cited weaknesses in internal controls, staffing and training, as well as customer identification and due diligence. The bank periodically reported suspicious activity, the OCC said, but lacked the capabilities and controls to identify and report its full scope in a timely way.