Fed, OCC order Amex to overhaul AML controls

• Key insight: The Federal Reserve and Office of the Comptroller of the Currency separately ordered American Express to remediate widespread anti-money-laundering and financial-crime control deficiencies.
• Supporting data: Amex processed about $13 billion in suspected trade-based money laundering activity from 2014 to 2025, including transactions involving bank insiders, according to the agencies.
• Forward look: The OCC ordered an independent look-back to examine whether additional suspicious activity reports should have been filed, while the Fed required the parent companies to submit remediation plans.

Regulators fined American Express’ banking arm $350 million on Thursday for insufficient anti-money-laundering controls, while the Federal Reserve ordered Amex’s parent companies to address financial-crime deficiencies across the enterprise. 

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The Federal Reserve and Office of the Comptroller of the Currency, in separate, coordinated cease-and-desist actions, ordered American Express to overhaul its anti-money-laundering compliance after regulators found widespread deficiencies.

“Recent supervisory assessments of Amex conducted by the Federal Reserve Bank of New York identified significant deficiencies in Amex’s enterprisewide financial crimes risk management program, including weaknesses in transaction monitoring, fraud referral processes, third-party risk assessment, and financial crimes risk management,” the Fed said in its enforcement action.

The OCC, which fined Amex $350 million as part of its enforcement action, said they identified roughly $13 billion in illicit activity at the firm, including transactions with ties to bank “insiders.”

“From approximately June 2014 to approximately May 2025, the Bank processed approximately $13 billion in suspected [trade-based money laundering] activity, including a combination of suspicious card charges and associated repayments of those card charges, and including in certain instances through accounts associated with Bank insiders,” the OCC action stated. “Weaknesses in the Bank’s controls surrounding [suspicious activity reports] were significant and resulted in untimely, missed, or incomplete SARs, relating both to suspected trade-based money laundering activity and other suspicious activity.”

Amex Chairman and CEO Stephen J. Squeri said in a statement that the bank “takes its responsibility to combat financial crimes seriously” and that it is “fully committed to addressing the concerns outlined by the FRB and OCC and continuing to strengthen our Financial Crimes Compliance program.

“Over the last few years, we have engaged closely with regulators as we have strengthened our controls and with law enforcement to provide information,” Squeri continued. “We have made and continue to make substantial investments in our people, technology, training, governance, and oversight to fortify how we identify, assess, and respond to evolving financial crimes risk across our business and the industry.”

Squeri added that the orders do not impose an asset cap on the bank and the civil penalties are not expected to affect the bank’s 2027 forward guidance. 

The OCC’s order, directed at American Express National Bank, criticized the firm’s know-your-customer processes, suspicious activity reporting procedures and staff training on AML requirements. The bank will be required to establish a board-level compliance committee to develop its process for improving compliance and develop a comprehensive remediation plan.

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Regulators are also requiring an independent look-back to determine whether additional suspicious activity reports should have been filed. The look-back will be provided to the examiner-in-charge for the bank. 

“The OCC expects banks of American Express’s size and complexity to devote sufficient resources to ensure compliance with laws and regulations designed to detect and prevent money laundering, which are critical to both economic and national security,” said Comptroller of the Currency Jonathan Gould. “American Express failed to maintain a BSA/AML compliance program properly aligned with the money laundering risks of its operations, which resulted in the bank’s failures to timely identify and report significant missed suspicious activity and to provide important information to law enforcement.” 

The Federal Reserve’s order is directed to the bank’s parent companies — American Express Co. and American Express Travel Related Services — and focuses on financial-crimes risk management shortcomings at the holding company level. The Fed said it found weaknesses in American Express’ transaction monitoring processes for referring fraud to authorities, third-party and financial crime risk management. The Fed will also require the company to submit plans addressing those areas.

American Express must also cooperate with the Fed in investigations of employees and other individuals involved in the misconduct underlying the order.

Just last month, the Federal Reserve and Federal Deposit Insurance Corp. expressed doubt about the feasibility of American Express’ resolution plan. Regulators had no formal objections to any of the 15 plans under review, but expressed concern about the firm’s plan that envisioned selling its bank, operating company and parent-company assets together in a single sale.

Regulators said that may not be feasible because the FDIC would be in charge of selling the bank side of the business and bankruptcy court would run a separate sale process for the remainder, meaning the two parties may not produce the same winning bidder. 

American Express did not immediately respond to a request for comment.