The Office of the Comptroller of the Currency has issued a cease-and-desist order and a $350 million civil money penalty against American Express National Bank for deficiencies in its Bank Secrecy Act and anti-money laundering compliance program.
The penalty was set out in an Oct. 8 consent order, in which the bank neither admitted nor denied the findings.
The OCC said the Sandy, Utah, bank failed to establish a program reasonably designed to monitor BSA compliance. The agency cited inadequate resources, including staff without enough expertise, along with systemic internal control gaps, weak independent testing, and weak training for employees and directors.
At the center of the case is about $13 billion in suspected trade-based money laundering activity, which the OCC said the bank failed to identify, evaluate, and report on time. The C&D order says the activity ran from roughly June 2014 to May 2025 and included suspicious card charges and repayments, in some cases through accounts tied to bank insiders. The bank filed some suspicious activity reports during that period, but lacked the controls to catch the full scope.
The OCC said the bank’s risk assessment was not tailored to its business. It focused on its narrow deposit products and gave too little attention to its dominant credit and charge card business. Customer due diligence and customer identification gaps made the monitoring failures worse.
Comptroller Jonathan Gould said in a press release that the bank failed to maintain a program “properly aligned with the money laundering risks of its operations.” He added that the OCC expects banks of American Express’s size and complexity to devote enough resources to compliance.
The Federal Reserve issued a concurrent C&D order against American Express and American Express Travel Related Services. The OCC penalty goes to the U.S. Treasury.