American Express National Bank has about 90 days to give federal regulators a written plan for fixing its anti-money-laundering controls. The Office of the Comptroller of the Currency signed a consent order on October 8 and assessed a $350 million civil money penalty. The agency says the bank did not adequately report roughly $13 billion in suspected money laundering.
What the OCC ordered
The OCC announced a cease-and-desist order and the penalty against American Express National Bank, based in Sandy, Utah, over deficiencies in its Bank Secrecy Act and anti-money-laundering program. The penalty is paid to the U.S. Treasury. In the order, the bank “neither admits nor denies” the Comptroller’s findings.
Under the consent order, the bank must submit a written Action Plan to its OCC examiner-in-charge within 90 days. The OCC then decides whether it has “no supervisory objection.” The plan has to set timelines and name responsible people for each fix. Counted from October 8, the 90 days end around January 6, 2027.
Other clocks are shorter. A compliance committee, with a majority of independent directors, must be appointed within 15 days. It has to meet at least quarterly and report to the board within 30 days after each quarter. Those deadlines belong to the bank. The order asks nothing of cardholders, and the OCC announced no customer restitution.
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What the OCC says went wrong
The OCC says the bank’s risk assessment did not fit its business. It focused on the bank’s relatively narrow demand deposit products and gave too little attention to its much larger credit and charge card businesses.
The figure at the center is $13 billion. The order says that from about June 2014 to May 2025 the bank processed roughly that much in suspected trade-based money laundering, a scheme that moves illicit money by disguising it as international trade. Some of the activity ran through accounts linked to bank insiders.
Other failures run through the findings. The OCC cites gaps in customer due diligence and customer identification, breakdowns in monitoring and reporting suspicious activity, an ineffective internal audit, too few staff and weak training. It calls the violations part of a pattern of misconduct that caused more than a minimal loss.
Comptroller Jonathan Gould said the bank “failed to maintain a BSA/AML compliance program properly aligned with the money laundering risks.” He added that today’s actions “will serve to focus American Express on properly addressing such risks.” He called such programs critical to both economic and national security.
The OCC coordinated its action with a separate cease-and-desist order from the Federal Reserve Board. That order targets American Express Company and American Express Travel Related Services Company, Inc.. The Fed’s terms are in its own order, which the OCC release does not describe.
What the bank has to build
The bank must write an institution-wide risk assessment, refresh it at least every 12 months and have it independently tested every year. It must also adopt a written customer due diligence program covering risk ratings, enhanced due diligence for riskier customers and ongoing monitoring.
The bank must also build a financial crimes risk management program. It covers front-line controls, third-party risk, and limits and controls on ACH transactions, the electronic transfers that move payroll and bill payments. The bank must strengthen how it identifies suspicious activity, handles alerts and files reports, and address backlogs.
A look-back is part of the order. The bank has to hire an independent consultant, subject to OCC approval, to review past suspicious activity and the reports it filed. The consultant’s report is due within 60 days of finishing the review, and the OCC can require additional work.
The order also covers staffing and people. The bank must assess its anti-money-laundering staff and skills, add to them and set up a succession plan. It must train directors and employees according to risk and set up a program to monitor insider risk, with reporting and disciplinary referrals.
The board is responsible for making sure each fix is adopted, effective and enforced. The bank gives up its rights to a hearing and an appeal. The order does not release it from actions by other government bodies, including the Department of Justice, and the OCC keeps the right to assess more penalties if violations continue.
A week later, a larger penalty at another bank
The $350 million sits next to a bigger number. On October 13 the OCC announced a $750 million penalty against Bank of America for deficient anti-money-laundering compliance, which it called the largest in its history. That penalty is also paid to the Treasury, and the OCC release mentions no customer restitution.
Gould said in that release that banks without effective anti-money-laundering programs “can expect swift and significant action from the OCC.” Two announcements within a week show the agency using penalties and written fix plans against large banks. Neither announcement sends money to account holders.
Will the fix plan change anything on a card account?
Orders like this one put deadlines on banks, not payments in customers’ hands. The $350 million goes to the Treasury, and no refund to cardholders has been announced.
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
