- The OCC found American Express National Bank processed approximately $13 billion in suspected trade-based money laundering from June 2014 to May 2025, including accounts tied to bank insiders.
- The bank agreed to a $350 million consent order for failing to maintain an effective Bank Secrecy Act and anti-money laundering program.
- The Federal Reserve issued a separate enforcement action barring retention of individuals linked to the misconduct.
- American Express said part of the penalty was already reserved and won’t affect full-year 2026 guidance.
The Office of the Comptroller of the Currency (OCC) found that American Express National Bank processed approximately $13 billion in suspected trade-based money laundering (TBML) between June 2014 and May 2025. The alleged activity included suspicious card charges and associated repayments, including in certain instances through accounts associated with bank insiders.
The OCC and American Express National Bank agreed to a consent order requiring the bank to pay $350 million for failing to maintain an effective Bank Secrecy Act (BSA) and anti-money laundering (AML) program. Consequently, the Federal Reserve issued a separate enforcement action over similar BSA/AML failures.
The Federal Reserve enforcement action bars American Express from directly or indirectly retaining any individual who participated in the misconduct, was formally disciplined for it, or separated from the firm in connection with it. Meanwhile, TBML is a form of money laundering that manipulates trade transactions—such as inflated invoices—to legitimize dirty funds.
In this case, the conduct appears tied to how American Express credit cards were used. American Express‘s Form 8-K filed with the SEC claimed that a portion of the civil money penalty was reserved in prior periods and does not impact full-year 2026 guidance. It added that the penalty is not anticipated to affect the company’s 2027 guidance.
While not the largest in OCC history, the $350 million penalty ranks near the $450 million order against TD Bank in 2024.
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