Fed and OCC order Amex to overhaul AML controls

Overview

Updated 42 minutes ago

American Express National Bank agreed to pay a $350 million fine and overhaul its anti-money-laundering program after regulators found it processed roughly $13 billion in suspected trade-based money laundering from June 2014 to May 2025. The Office of the Comptroller of the Currency (OCC) issued a cease-and-desist order against the bank, while the Federal Reserve ordered parent companies American Express Co. and American Express Travel Related Services to fix financial-crimes risk management company-wide.

Regulators said the bank's risk assessment focused on its deposit accounts and underweighted its dominant credit and charge card business, leaving systemic gaps in suspicious activity monitoring and reporting. The OCC also required an independent look-back to determine whether additional suspicious activity reports should have been filed. The orders do not impose an asset cap, and Amex said a portion of the penalty was already reserved in prior periods.

Why it matters

If card issuers must tailor anti-money-laundering controls to card products, not just deposits, the compliance cost structure of the entire US card industry changes.

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Key Indicators

$350M

Civil money penalty against American Express National Bank

Assessed by the OCC; a portion was reserved in prior periods and does not affect 2026 guidance.

$13B

Suspected trade-based money laundering processed

From approximately June 2014 to May 2025, including suspicious card charges and associated repayments.

2 regulators

Federal agencies issuing consent orders

The OCC acted against the bank; the Federal Reserve acted against the parent companies.

Voices

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People Involved

Rodney E. Hood

Comptroller of the Currency

OCC head during the enforcement action

Stephen Squeri

Chairman and CEO, American Express

Overseeing compliance remediation per the consent orders

Organizations Involved

Office of the Comptroller of the Currency

Federal Agency

Primary regulator of American Express National Bank; assessed penalty and issued cease-and-desist order

The OCC charters, regulates, and supervises national banks and federal savings associations. It determined the bank failed to maintain a BSA/AML compliance program reasonably designed to assure compliance.

Board of Governors of the Federal Reserve System

Federal Agency

Issued consent order against American Express Co. and American Express Travel Related Services

The Federal Reserve's order addresses financial-crimes risk management shortcomings at the holding company level, including transaction monitoring and third-party risk management.

American Express

Public Company

Consented to both orders; bank pays $350 million penalty

American Express National Bank is one of the largest credit and charge card issuers in the US by transaction volume. The company consented to the OCC and Fed orders on October 8, 2026.

Timeline

June 2014 October 2026

5 events Latest: Yesterday

Tap a bar to jump to that date

October 2026
OCC fines Amex bank $350 million
Latest Enforcement

OCC issues cease-and-desist order and $350 million penalty against American Express National Bank.
Yesterday
Federal Reserve orders parent companies to fix AML controls
Enforcement

Fed issues consent order against American Express Co. and American Express Travel Related Services for financial-crimes risk management shortcomings.
Yesterday
Amex consents to orders, confirms penalty
Statement

Amex files 8-K confirming consent to both orders; says portion of penalty was already reserved.
Yesterday
May 2025
Suspected laundering period ends
Investigation

The OCC's findings cover suspected trade-based money laundering through approximately May 2025.
May 2025
June 2014
Suspected trade-based money laundering begins
Investigation

Approximately $13 billion in suspected money laundering activity begins processing, per the OCC's findings.
June 2014

Scenarios

Independent look-back finds additional SARs were required

Possible Resolves by End of 2027

Discussed by: American Banker, theclarity.today

The OCC requires an independent reviewer to examine whether Amex should have filed additional suspicious activity reports for activity it processed over the past decade. If the reviewer finds a significant backlog of missed filings, remediation stretches longer and the consent orders stay open while it is cleared. This could extend the cost of the compliance overhaul well beyond the $350 million penalty.

Look-back finds few missed SARs; remediation costs stay contained

Possible Resolves by End of 2027

Discussed by: theclarity.today

If the independent reviewer determines that most of Amex's existing suspicious activity reports were adequate, much of the spending Amex describes is already in its cost base. The orders then cost little beyond the fine, and the company moves to board-level compliance oversight without a prolonged enforcement period.

Card-industry AML standards tighten industry-wide

Possible Resolves by End of 2028

Discussed by: American Banker

Examiners now have a written OCC finding that a card-dominant bank sized its money-laundering risk around its deposit products. Regulators can apply this test to other card lenders that take deposits, potentially forcing the entire industry to re-weight risk assessments toward card and charge products. This could raise compliance costs across the sector.

Historical Context

2 moments from history that rhyme with this story — and how they unfolded.

December 2012

HSBC money laundering settlement (2012)

HSBC agreed to pay $1.9 billion after US investigators found the bank laundered billions of dollars for Mexican drug cartels and circumvented sanctions on Iran, Cuba, and other countries. The bank failed to monitor $670 billion in wire transfers from Mexico and allowed terrorists to access the US banking system.

Then

HSBC entered a deferred prosecution agreement and overhauled its compliance program under monitor oversight. The bank kept its US banking license, which critics said was too lenient.

Now

The settlement became a template for large-bank AML enforcement: big financial penalties paired with compliance overhauls and monitor appointments. It also fueled the 'too big to jail' critique of US financial enforcement.

Why this matters now

Like HSBC, Amex faces a large penalty tied to systemic AML program failures. Both cases show regulators pairing fines with mandated compliance restructurings — the question is how much the remediation costs on top of the penalty.

June 2010

Wachovia money laundering case (2010)

Wachovia paid $160 million after investigators found it failed to monitor $378 billion in transactions for Mexican currency exchanges, helping drug cartels launder money. The bank settled without admitting wrongdoing.

Then

Wachovia entered a deferred prosecution agreement, closed its currency exchange business, and hired outside monitors. The case contributed to the bank's reputational damage before Wells Fargo acquired it in 2008.

Now

The case showed how gaps in transaction monitoring — even without intent — could produce massive laundering exposure. It pushed banks to invest in automated monitoring systems.

Why this matters now

Both cases hinge on systemic monitoring failures rather than individual misconduct. Amex's path will likely mirror Wachovia's: mandated process fixes, monitor oversight, and prolonged regulatory scrutiny.