American Express $350M AML Fine: What Regulators Found

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The OCC fined American Express $350 million over anti-money-laundering failures, and the Fed issued its own order after about $13 billion in suspected laundering went undetected.

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The Office of the Comptroller of the Currency fined American Express (AXP) $350 million on October 8, 2026, citing deficiencies in its anti-money-laundering program. The agency issued a cease-and-desist order against American Express National Bank, which is based in Sandy, Utah. The Federal Reserve announced a separate cease-and-desist action against the parent company and its travel-related services arm. Regulators found that the company failed to identify, investigate and report about $13 billion in suspected trade-based money laundering activity between June 2014 and May 2025.

What Did Regulators Find at American Express?

Regulators found systemic breakdowns in how American Express monitored and reported suspicious activity. The OCC cited inadequate resources for the compliance program, understaffing, poorly trained employees and directors, gaps in internal controls, and a lack of independent testing.

The agency said the bank's risk assessment was not tailored to its actual business. The framework leaned heavily toward deposit account products, which left the larger credit and charge card operations without adequate scrutiny. Some of the flagged activity involved credit cards, and some involved accounts linked to bank insiders.

What Does the Order Require?

The orders require American Express to rebuild core compliance functions on fixed deadlines. Under the OCC order, the national bank has 90 days to submit a compliance action plan. It must also:

• Develop an effective Bank Secrecy Act and anti-money-laundering risk assessment process.
• Establish a customer due diligence and risk identification program.
• Engage a third party to conduct a look-back review of suspicious activity.

The Fed's order requires American Express to submit an enterprise-wide improvement plan for BSA/AML compliance risk management. The travel-related services subsidiary must also submit a plan for compliance with sanctions rules administered by the Treasury's Office of Foreign Assets Control.

How Has American Express Responded?

Chief Executive Stephen Squeri said the company takes its responsibility to combat financial crime seriously and acknowledged that "there is more work to do." He said a portion of the civil money penalty was reserved in prior periods. American Express said the penalty does not affect its full-year 2026 guidance or its anticipated 2027 guidance.

How Does This Compare With Other Bank AML Cases?

The penalty is smaller than the largest recent cases in the sector. The OCC's previous civil money penalty of comparable scale was the $450 million levied on TD Bank in October 2024. TD Bank's total penalties across agencies exceeded $3.5 billion, and it also accepted an asset cap on its U.S. retail operations. Neither the OCC nor the Fed order for American Express imposes a growth restriction, based on the terms disclosed so far.

The action shows that U.S. bank supervisors are applying anti-money-laundering rules to card issuers and payment networks, not only to deposit-focused banks. For large card issuers, the case underlines the need to build monitoring that covers credit and charge products as thoroughly as deposit accounts.

Strategic Context

American Express runs a closed-loop network and relies on affluent cardholders and corporate clients. Its cross-border and commercial payments business exposes it to trade-related transaction flows. The orders will require sustained spending on compliance staff, systems and independent testing, and a third-party look-back could surface additional reportable activity.

Outlook

American Express faces a 90-day deadline to submit its plan to the OCC, followed by implementation under regulatory supervision and the third-party review of past transactions. The $350 million penalty is largely accounted for, according to the company, and the company has kept its earnings guidance unchanged. The main open questions are the findings of the look-back and how the Fed's plans are received.