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The Office of the Comptroller of the Currency imposed a $350 million civil money penalty on American Express National Bank and issued a cease-and-desist order over deficiencies in its Bank Secrecy Act and anti-money-laundering program. The Federal Reserve separately issued an enforcement action against American Express Company and American Express Travel Related Services Company over suspicious-activity reporting and companywide AML controls.
The Office of the Comptroller of the Currency fined American Express National Bank $350 million and issued a cease-and-desist order after finding deficiencies in the bank’s Bank Secrecy Act and anti-money-laundering compliance program. On the same day, the Federal Reserve issued a separate enforcement action against American Express Company and American Express Travel Related Services Company over the handling of suspicious activity and implementation of the company’s enterprise-wide AML program.
The OCC said its findings included inadequate resources for the compliance program, a risk assessment that was not sufficiently tailored to the bank’s business activities, and systemic breakdowns in processes for monitoring and reporting suspicious activity. The agency said the failures meant the bank had not established and maintained an adequate program under the Bank Secrecy Act and related AML requirements. Its order applies to American Express National Bank, and the $350 million civil money penalty was assessed against that bank.
The Federal Reserve described its action as addressing American Express Company’s failure to sufficiently detect and report suspicious activity related to money laundering, along with deficiencies in how its enterprise-wide AML program was implemented. The Fed’s cease-and-desist order names American Express Company and American Express Travel Related Services Company. The supplied statements do not specify a separate Fed penalty amount.
American Express said the regulators’ reviews had been disclosed previously. Chairman and Chief Executive Officer Stephen J. Squeri said the company had worked with regulators over the past few years to strengthen controls and with law enforcement to provide information about transactions in which individuals misused its products. The company acknowledged that work remains, while the regulators’ announcements set out formal enforcement actions and the OCC’s penalty.
Regulatory Orders Put AML Controls Under Scrutiny
The actions address a core obligation for banks and financial firms: identifying activity that could indicate money laundering and reporting it to authorities. The OCC said the problems involved both staffing and the design and operation of monitoring systems, rather than a single isolated control. Its stated expectation is that institutions of American Express’s size and complexity have adequate resources to meet those requirements.
For customers and the financial system, effective monitoring and reporting can help law enforcement trace suspicious transactions and deter the misuse of financial products. The orders signal that regulators found shortcomings serious enough to require formal corrective action. The $350 million OCC penalty is a specific financial consequence for the bank; the Federal Reserve’s action extends regulatory scrutiny to the parent company and a related services subsidiary. The announcements do not, by themselves, establish that any particular customer or transaction was involved in wrongdoing.
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Two Agencies Address Different Entities
The OCC supervises national banks, including American Express National Bank, and its announcement tied the bank’s deficiencies to its BSA/AML compliance program. The Federal Reserve’s action named American Express Company and American Express Travel Related Services Company, focusing on suspicious-activity detection and reporting and the implementation of the wider company program. The actions were announced on October 8, 2026, and should be understood as separate orders by separate regulators, not a single combined penalty.
American Express said the regulatory reviews had been disclosed before the orders were issued. Squeri said the company had been working with regulators to strengthen controls over the preceding years and cooperating with law enforcement regarding transactions involving misuse of its products. The source material does not provide the dates when the reviews began or a detailed account of earlier disclosures, so the length and milestones of the regulatory process cannot be established from the announcements described.
“While we have made meaningful progress, we know there is more work to do.”
— Stephen J. Squeri, American Express chairman and CEO
Corrective Milestones Are Not Detailed
The announcements described in the source material do not give a timeline for completing corrective work, specific milestones, or details of how regulators will assess whether the deficiencies have been remedied. The OCC release identifies categories of problems but does not provide transaction-level examples or quantify the number of alerts or reports affected.
The Federal Reserve’s statement, as summarized in the source, does not specify a separate monetary penalty. It is also not clear from the material whether either agency’s order includes requirements beyond the stated cease-and-desist actions, or what additional public reporting may follow. The regulators’ findings concern compliance deficiencies; the available information does not identify individual customers or establish that particular transactions constituted money laundering.
Compliance Work and Regulatory Follow-Up
American Express said it would continue working with regulators and law enforcement and building its Financial Crimes Compliance program. The next steps will depend on the requirements in the full OCC and Federal Reserve orders and the company’s implementation of any required corrective measures. The source material does not state a deadline for those measures or describe a scheduled follow-up examination.
Further public updates could clarify the remediation timetable, the monitoring and reporting changes, and how the agencies will judge progress. Until such details are released, the confirmed developments are the OCC’s $350 million penalty and cease-and-desist order against American Express National Bank and the Fed’s separate order naming the parent company and Travel Related Services Company.
Key Questions
What penalty did the OCC impose?
The OCC imposed a $350 million civil money penalty on American Express National Bank and issued a cease-and-desist order.
What deficiencies did the OCC identify?
The OCC cited inadequate program resources, a risk assessment not sufficiently tailored to the bank’s business activities, and systemic breakdowns in suspicious-activity monitoring and reporting.
Which companies were named in the Federal Reserve action?
The Federal Reserve’s cease-and-desist order named American Express Company and American Express Travel Related Services Company. The source material does not state a separate Fed penalty amount.
What has American Express said it will do?
CEO Stephen J. Squeri said the company would continue cooperating with regulators and law enforcement and working to strengthen its Financial Crimes Compliance program. He said the company had made progress but still had more work to do.
When will the corrective work be completed?
The available announcements do not provide a completion date, detailed milestones, or a timetable for regulators’ follow-up assessments.
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