American Express Fined $350M Over Decade-Long Suspected Money Laundering
Regulators allege American Express missed a decade of suspicious transaction alerts
American Express National Bank is facing a $350 million fine after US regulators found it failed to maintain an effective anti-money laundering program for roughly ten years. The Office of the Comptroller of the Currency (OCC) and the Federal Reserve both took action against the company.
The OCC alleges the bank processed around $13 billion in suspected trade-based money laundering between June 2014 and May 2025. Some of the activity involved accounts linked to bank insiders.
Key details of the penalty
- American Express will pay a $350 million civil money penalty under a consent order with the OCC.
- The suspected money laundering involved suspicious credit card charges and associated repayments.
- The Federal Reserve also issued an enforcement action for similar failures to meet anti-money laundering requirements.
- The Fed order bars American Express from retaining individuals who participated in the misconduct or faced formal disciplinary action related to it.
- American Express stated the fine does not impact its full-year 2026 or 2027 financial guidance.
What the OCC consent order says
The OCC found that American Express failed to maintain an effective Bank Secrecy Act and Anti-Money Laundering program. The behavior allegedly spanned from approximately June 2014 to May 2025.
The bank processed "approximately $13 billion in suspected trade-based money laundering activity," according to the OCC consent order. This included a combination of suspicious card charges and repayments, and in certain instances involved accounts associated with bank insiders.
Trade-based money laundering explained
Trade-based money laundering is a method of disguising illegally obtained funds by manipulating trade transactions. This can involve falsified invoices or over- and under-invoicing goods to make "dirty" money appear legitimate. In this case, the alleged activity was connected to how American Express credit cards were used.
How the penalty compares
The $350 million fine is not the largest in OCC history, but it is substantial. It ranks near the $450 million order the OCC imposed on TD Bank in 2024.
Why this matters for financial crime compliance
The case highlights continued regulatory scrutiny of anti-money laundering programs across the financial sector. Both the OCC and Federal Reserve took parallel actions, signaling that institutions face consequences from multiple regulators when compliance systems fail over extended periods.
What happens next
Under the OCC consent order, American Express must implement corrective measures to strengthen its anti-money laundering program. The Federal Reserve enforcement action includes the restriction on retaining certain employees connected to the misconduct.
Sources
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