meta_id 3576894

On October 8, 2026, the Office of the Comptroller of the Currency (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 Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance program. The OCC determined that American Express National 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. The deficiencies included inadequate resources, staff without sufficient expertise, systemic internal control gaps, weak independent testing, and insufficient BSA/AML training for employees and directors. The bank failed to tailor its BSA/AML risk assessment to its business activities, focusing narrowly on demand deposit account products while insufficiently addressing risks in its more dominant credit and charge card products. The bank's customer due diligence processes and customer identification program procedures contributed to monitoring and reporting failures. Most significantly, American Express National Bank 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 over the past decade. Comptroller of the Currency Jonathan Gould said the OCC expects banks of American Express's size and complexity to devote sufficient resources to ensure compliance with laws and regulations designed to detect and prevent money laundering. The OCC is taking these actions in coordination with a concurrent cease-and-desist order against American Express Company and American Express Travel Related Services Company, Inc., issued by the Board of Governors of the Federal Reserve System. The OCC-assessed penalty will be directed to the U.S. Treasury.