American Express has been fined $350 million by U.S. bank regulators, who say the company's national bank subsidiary maintained an insufficient anti-money laundering compliance program for years while billions of dollars in suspicious activity went unreported. The Office of the Comptroller of the Currency and the Federal Reserve both announced enforcement actions against the company, pointing to systemic breakdowns in how the bank monitored and flagged potentially illicit transactions.
According to Reuters, the penalty stems largely from the conduct of American Express's national bank, which regulators say was the primary entity involved. The OCC, which fined Amex $350 million as part of its enforcement action, according to American Banker, found that the bank processed approximately $13 billion in suspected trade-based money laundering activity from approximately June 2014 to approximately May 2025. A separate account from Banking Dive describes the same rough dollar figure but frames it as roughly $13 billion of suspected money laundering activity over the past 10 years, so the precise time window tied to that number is described differently depending on the source.
Regulators Detail Where the Compliance Program Broke Down
Per Reuters, American Express had inadequate resources, inexperienced staff and weak training within its anti-money laundering program, along with internal control gaps. The company also had shortcomings in both its customer due diligence programs and its customer identification programs, per the OCC's findings as relayed by Reuters. Those gaps left the bank unable to identify, evaluate or sufficiently report roughly $13 billion in suspicious activity over the past decade, according to the OCC's findings cited by Reuters.
The Federal Reserve's enforcement action pointed to its own set of weaknesses, including transaction monitoring, fraud referral processes, third-party risk assessment, and financial crimes risk management, as reported by American Banker. The Fed characterized the problems as enterprise wide, but particularly an issue at its national bank subsidiary, the same outlet's report notes.
A Mismatch Between Where Amex Looked and Where the Risk Actually Was
One of the more pointed findings from the OCC, as described by Banking Dive, is that American Express spent too much attention on its relatively narrow demand deposit account products and services, while not devoting sufficient attention to its much larger and more dominant credit and charge card business, which generates far more transaction volume. The bank also failed to tailor its Bank Secrecy Act and anti-money laundering risk assessment to its actual business activities, Banking Dive reported, a mismatch regulators say contributed to the scale of the monitoring failures.
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, according to Reuters. The remediation required under the orders goes beyond the dollar penalty. The bank will be required to establish a board-level compliance committee to develop its process for improving compliance and develop a comprehensive remediation plan, American Banker reported, with an independent look-back of potentially unfiled suspicious-activity reports also part of the response.
Amex Responds Without Admitting Wrongdoing
American Express did not admit or deny the regulators' findings as part of the resolution, per Reuters' reporting. The company said Thursday that it takes its responsibility to combat financial crimes seriously, and that it will address the concerns of both the Fed and the OCC, according to Banking Dive.
This is not the first time American Express has faced coordinated federal scrutiny over compliance functions. A Federal Reserve enforcement action from 2012 found that deficiencies in compliance risk management and internal audit, which are firm-wide functions at Amex, allegedly allowed earlier practices to occur, according to the Federal Reserve's own records. The company's broader AML struggles echo industry-wide pressure points: a 2024 OCC consent order against TD Bank similarly cited a customer due diligence violation and unsafe or unsound practices tied to that bank's BSA/AML compliance program, underscoring that large financial institutions continue to face scrutiny over how well they screen for illicit activity even as regulators have pushed a risk-based approach to customer due diligence since at least 2022.
