American Express has been hit with a $350mn penalty for “critical deficiencies” in its compliance programme that led it to miss about $13bn of suspected money laundering activity for more than a decade.
The Office of the Comptroller of the Currency, an arm of the US Treasury and one of the country’s main bank regulators, said on Thursday that the failings by American Express’s US national bank subsidiary under anti-money laundering rules had been “systemic”.
These deficiencies included insufficient staff expertise and training, internal control gaps and independent testing weaknesses. The bank, which is one of the largest issuers of credit and charge cards in the US, neither admitted nor denied the findings by the OCC.
American Express failed to maintain a compliance programme “properly aligned with the money laundering risks of its operations”, said Comptroller of the Currency Jonathan Gould.
This “resulted in the bank’s failures to timely identify and report significant missed suspicious activity and to provide important information to law enforcement”, he added.
The OCC said American Express failed to identify and report about $13bn in suspected trade-based money laundering activity in a timely manner from 2014 to 2025, “including in certain instances through accounts associated with bank insiders”.
Trade-based money laundering refers to the practice of disguising illicit proceeds in remittances by mispricing goods or inflating invoices.
The Bank Secrecy Act imposes a series of reporting, record-keeping and other requirements on financial institutions and other businesses, which are shared with the Treasury to help prevent money laundering, tax evasion and other criminal activities.
A core component of the BSA is the filing of Suspicious Activity Reports with law enforcement and banking regulators whenever banks “know or suspect suspicious or potential criminal activity”. American Express National Bank had “systemic breakdowns” in its SARs filing regime, which “resulted in a pattern or practice of non-compliance”, according to the consent order published by the OCC.
The Federal Reserve Board also issued a cease-and-desist order against American Express and American Express Travel Related Services, its subsidiary through which much of its card and payment business is processed.
Shares in American Express, which said the penalty would not impact the company’s financial outlook for 2026, were down almost 2 per cent in after-hours trading.
In a statement, Stephen Squeri, American Express chair and chief executive, said the company took its “responsibility to combat financial crimes seriously” and was “fully committed” to addressing the concerns of the OCC and Federal Reserve Board.
The OCC required American Express to appoint a committee within 15 days to monitor the bank’s compliance with the consent order and oversee its efforts to address the issues.
The bank is also required to submit for review a detailed remediation plan to achieve and maintain compliance with the BSA within 90 days to the OCC and appoint an independent consultant to review historic suspicious transactions.