On October 8, 2026, the OCC announced a cease-and-desist order and a $350 million civil money penalty against American Express National Bank, Sandy, Utah, for deficiencies in the bank’s BSA and AML compliance program. The OCC found that the bank failed to establish and maintain a BSA/AML compliance program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations.
In particular, the OCC found that American Express:
Did not properly align its BSA/AML risk evaluation with actual operations, concentrating primarily on limited demand deposit offerings while neglecting exposure within its primary credit and charge card portfolios;
Experienced systemic breakdowns in its suspicious activity monitoring and reporting processes, resulting in a failure to timely identify, evaluate, and sufficiently report approximately $13 billion of suspected trade-based money laundering activity that took place over the past decade.
The Federal Reserve Board issued a separate enforcement action against the bank to address, among other things, the firm's failure to sufficiently detect and report certain suspicious activity related to money laundering.
Read the OCC’s press release here.
The Federal Reserve’s Order can be found here.