American Express to pay $350M for failing to prevent money laundering over a decade

The Office of the Comptroller of the Currency (OCC) determined that American Express National Bank handled roughly $13 billion in suspected trade-based money laundering (TBML) from June 2014 through May 2025, with some transactions occurring through accounts belonging to bank insiders.

A consent order between the OCC and American Express National Bank requires the bank to pay $350 million due to its inability to sustain a proper Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) program.

The Federal Reserve also issued an enforcement action against American Express for analogous shortcomings in meeting BSA/AML standards.

According to the OCC consent order, the misconduct lasted from around June 2014 to May 2025, during which the bank handled “approximately $13 billion in suspected TBML 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.”

TBML is a money-laundering method that relies on tampering with trade deals, such as through falsified invoices, to legitimise funds derived from illegal activity.

In this instance, the suspected money laundering appears connected to how American Express credit cards were employed.

The Federal Reserve's enforcement action prohibits American Express from “directly or indirectly retaining any individual as an officer, employee, agent, consultant, or contractor of the firm or any subsidiary or affiliate thereof who, based on the investigative record compiled by the firm during the period 2024 to the present: (i) participated in the misconduct underlying this order; (ii) was subjected to formal disciplinary action as a result of the firm’s internal disciplinary or performance reviews in connection with the misconduct underlying this order; and (iii) either separated from the firm or had his or her employment legally terminated in connection with the misconduct underlying this order.”

In a Form 8-K submitted to the SEC, American Express stated that “[a] portion of the civil money penalty was reserved for in prior periods and it does not impact the full-year 2026 guidance.”

The filing also says the penalty is “not anticipated to affect the company’s 2027 guidance.”

Although not the biggest penalty ever imposed by the OCC, this $350 million fine is still significant, placing it close to the $450 million action against TD Bank in 2024.