American Express's bank agreed to a $350M OCC fine over $13B of unflagged laundering

On October 8, 2026, the OCC fined American Express National Bank $350 million in a consent order, finding systemic breakdowns in suspicious-activity monitoring that failed to identify and timely report about $13 billion in suspected trade-based laundering over the past decade. The Sandy, Utah-based bank agreed; the money goes to the US Treasury. The same day the Federal Reserve issued a parallel consent order against the parent, American Express Company (Docket 26-052-B-HC) — no fine, but written plans on board oversight, the AML program and sanctions compliance due within 90 days.

The OCC named five weaknesses: inadequate resources and staff expertise, gaps in internal controls, weak independent testing, weak training, and customer due diligence and identification procedures that contributed to the failures. The bank's own risk assessment focused on its 'relatively narrow demand deposit products' and under-weighted its larger credit and charge card businesses, so the program was never tailored to where the money actually moved. Comptroller Jonathan Gould said the program was not 'properly aligned' with the bank's money-laundering risks.

Trade-based laundering moves value through the paperwork of commerce — misstating prices or quantities, invoicing goods more than once — and banks are the checkpoint expected to flag it in suspicious activity reports. The OCC stressed the $13 billion is a measure of suspected activity, not a finding of guilt against any customer; nothing in the releases says AmEx or its customers have been charged. CEO Steve Squeri said, 'While we have made meaningful progress, we know there is more work to do.'

$350M civil penalty to the US Treasury, plus a Federal Reserve consent order requiring AML rebuild plans within 90 days.

The bank's risk assessment was built around its deposit products and under-weighted its much larger card businesses, so monitoring pointed away from where the money moved.

Understaffing and weak expertise left suspicious-activity monitoring with systemic breakdowns that internal testing, training and controls failed to catch for years.

Trade-based laundering hides in invoices and trade documents, not account behavior; missing it for a decade left the government without the tips to follow the money.

A compliance program sized for the products you used to sell — not for the money that actually moves through you today — is how a card issuer's bank misses $13B of suspicious flows.

Both orders took effect October 8, 2026. The Fed's order bars the company from keeping anyone who took part in the misconduct and requires 'substantial assistance' to the Board; Amex must send the Fed the progress reports it files under the OCC's order (NR 2026-87). Amex had until early January to give the Federal Reserve Bank of New York its rebuild plans. Neither order requires closing accounts or contacting customers — the visible change for cardholders is likely more questions about identity and account usage, since customer due diligence is one of the areas regulators said fell short.