US regulators allege American Express failed to properly flag approximately $13bn in suspected money laundering proceeds, which were processed between 2014 and 2025 via commercial transactions
US banking regulators have imposed a $350m fine on American Express after it emerged that its anti-money laundering (AML) controls had failed to detect approximately $13bn in suspected illegal activity that had passed through the card issuer over an 11-year period.
The Office of the Comptroller of the Currency (OCC) has issued a cease-and-desist order and imposed a civil penalty on American Express National Bank due to shortcomings in its compliance programme relating to the Bank Secrecy Act (BSA) and AML.
The Federal Reserve took separate, coordinated action against the bank’s parent companies, American Express Co. and American Express Travel Related Services, focusing on financial crime risk management at holding company level.
American Express linked to $13bn in missed transactions
The OCC has said between June 2014 and May 2025, the bank processed approximately $13bn in suspected trade-related money-laundering activity, consisting of suspicious card spending and related refunds, with some of the transactions passing through accounts linked to the bank’s insiders.
The regulator attributed the shortcomings to ‘systematic failures’ in the way the bank monitored and reported suspicious transactions. Weak controls surrounding Suspicious Activity Reports (SARs) meant the organisation submitted reports that were either too late, were incomplete, or were not submitted at all.
The OCC also cited inadequate resources, inexperienced staff, poor training and shortcomings in internal controls, alongside deficiencies in customer due diligence and identification.
American Express focused its attention on AML risks associated with its relatively limited deposit products, according to the OCC, with not enough attention paid to its much larger credit card operations.
Comptroller of the Currency Jonathan Gould said a bank of American Express’s size and stature must devote sufficient resources to AML compliance, calling these laws “crucial to both economic and national security”.
He said Amex’s programme was not commensurate with the money-laundering risks posed by its activities, which led to a failure to make reports and to pass on key information to law enforcement agencies.
Regulators order review of SARs and board oversight
The OCC’s order requires the bank to establish a board-level compliance committee and draw up a comprehensive remediation plan. The bank must also commission an independent retrospective review to determine whether further SARs should have been filed, with the findings to be submitted to the relevant regulator.
The Fed stated that supervisory assessments by the Federal Reserve Bank of New York had revealed significant deficiencies in the bank’s enterprise-wide risk management in the area of financial crime, including transaction monitoring, fraud referral processes and third-party risk assessment.
The parent companies must submit plans to address these issues and must cooperate with the Fed’s investigations into employees and other individuals involved in the underlying misconduct.
Squeri rules out capital shortfall and negative impact on forecasts
Stephen Squeri, CEO of American Express, said the company is “fully committed to addressing the concerns raised by the FRB and OCC” and will continue to strengthen its financial crime compliance programme.
Squeri said that the company has worked closely with regulators and law enforcement agencies in recent years and has invested in staff, technology, training, governance and oversight.
Squeri acknowledged that, despite the progress made, there is still work to be done. He said the orders do not impose a cap on the bank’s assets, and the fine and the costs of meeting the regulators’ requirements are not expected to affect the forecasts for 2026 or 2027.
