About $13 billion in suspected trade-based money laundering went inadequately detected and reported through Amex over nearly 11 years. On October 8, 2026, the OCC imposed a $350 million civil money penalty on American Express National Bank for anti-money laundering failures, while the Federal Reserve issued a separate order carrying no fine.
If you use Amex, the orders address compliance failures, and no card or rewards changes have been announced. Amex says it faces no asset cap. Here are the key facts before you get into the details.
| Item | Detail |
|---|---|
| Date | October 8, 2026 |
| Penalty | $350 million imposed by the OCC, payable to the U.S. Treasury |
| Entities | American Express National Bank in Sandy, Utah, American Express Company and Travel Related Services Company, or TRS |
| Suspected laundering | About $13 billion between June 2014 and May 2025 |
| Asset cap | None |
| Guidance impact | Amex says its 2026 guidance remains unchanged |
| Admitted wrongdoing | No. Amex consented without admitting or denying the findings |
What Happened With the American Express Fine
You might read the headlines and think two regulators fined Amex. That is not what happened. The OCC imposed the $350 million penalty and issued a cease-and-desist order against the bank. The Federal Reserve separately ordered changes at American Express Company and TRS. Here is how those actions fit together.
The OCC supervises American Express National Bank, which sits under TRS. Its action addresses failures at the bank. The Fed’s order deals with financial crime controls across the parent companies and their operations, particularly the national bank.
The Federal Reserve announcement was released at 4.30 p.m. EDT on October 8. Amex accepted the orders without admitting or denying the allegations or findings. The Fed also acknowledged cooperation and corrective work already underway.
Why Regulators Penalized Amex
This was about more than a few missed transactions. Regulators found weaknesses in staffing, customer checks, reporting and oversight. You see, having a compliance programme is one thing. Making it work across your actual business is another. The findings explain where Amex fell short.
Gaps the OCC Found at the Bank
- Programme design. The bank’s Bank Secrecy Act and anti-money laundering programme did not adequately support compliance with its obligations.
- Risk assessment. It concentrated on a limited deposit business instead of giving sufficient attention to the much larger credit and charge card operation.
- Staffing and expertise. Resources were inadequate, including personnel with insufficient knowledge for the work required.
- Testing and training. Independent checks were weak, as was anti-money laundering training for employees and directors.
- Customer checks. Defects in customer identification and due diligence contributed to failures in transaction monitoring.
- Suspicious activity reporting. Systemic problems prevented timely detection, assessment and reporting of about $13 billion in suspected laundering. Some transactions involved accounts connected to unnamed bank insiders.
Comptroller Jonathan Gould’s message was that controls needed to match the bank’s risks, with enough resources for an institution of its size and complexity.
Problems the Federal Reserve Flagged
- Transaction monitoring. New York Fed reviews found serious weaknesses in the processes used to detect suspicious activity.
- Fraud referrals. The reviews identified problems in how suspected fraud was referred for further assessment.
- Third-party risk assessment. Reviews also found deficiencies in evaluating risks associated with outside parties.
What Trade-Based Money Laundering Means Here
In this case, the suspected activity involved transactions using Amex’s network. The company says individuals misused its services to purchase goods and services, and it reported investigated activity to law enforcement.
Keep the word “suspected” in mind when you read that $13 billion figure. The findings do not establish that every dollar was criminal proceeds. Amex had reported some suspicious activity, but its systems did not identify the full scale quickly enough.
Timeline of the Amex AML Case
The suspected activity spans years, while the October orders set deadlines for corrective work. The timeline puts those events in order.
| Date | Event |
|---|---|
| June 2014 | Start of the suspected laundering activity identified by the OCC |
| 2014 to 2021 | Conduct covered by the separate small-business sales-practices case |
| 2024 onward | Period covered by the internal investigative record referenced in the Fed order |
| January 16, 2025 | Amex agreed to a separate $230 million DOJ settlement |
| May 2025 | End of the suspected laundering period |
| October 8, 2026 | OCC penalty and regulatory orders issued |
| Within 15 days | OCC compliance committee must be formed |
| Within 90 days | Corrective plans must be submitted to both regulators |
| Within 45 days after each quarter | Progress reports due to the Fed |
What Amex Must Fix Under the Orders
Paying the penalty does not complete Amex’s obligations. The orders require written plans, stronger controls and continued reporting, with responsibilities reaching the board. You can see the main requirements and deadlines below.
| Requirement | Regulator | Deadline |
|---|---|---|
| Form a committee with at least three members, mostly independent directors | OCC | Within 15 days |
| Hold compliance committee meetings | OCC | At least quarterly |
| Submit an action plan with assigned responsibilities and completion dates | OCC | Within 90 days |
| Assess money laundering risks | OCC | At least annually |
| Improve customer identification, due diligence and risk identification | OCC | Required under the order |
| Arrange a third-party review of past suspicious activity reporting | OCC | Required under the order |
| Submit plans for board oversight and the enterprise BSA/AML programme | Fed | Within 90 days |
| Submit a TRS sanctions compliance plan covering assessment, training and screening | Fed | Within 90 days |
| Do not retain or rehire covered former participants who were disciplined and left | Fed | Continuing obligation |
| Cooperate with reviews and make current and former staff available for interviews | Fed | Continuing obligation |
| Submit progress reports | Fed | Within 45 days after each quarter |
What Amex Says About the Penalty
Amex says the orders resolve regulatory reviews it had already disclosed. Chief executive Stephen Squeri said the company treats financial crime prevention seriously and has been working on improvements. Here is what its response means for the financial outlook you may be following.
Part of the penalty had already been reserved in earlier periods. Amex says its full-year 2026 guidance remains unchanged, and it does not expect compliance costs to affect its 2027 guidance. The orders impose no asset cap.
The company described internal and external investigations, reports to law enforcement and spending on staff, technology, training and oversight. It also acknowledged that further work remains.
Investors still reacted. Shares fell about 2% in after-hours trading on October 8 and were down more than 16% for the year. If you are checking for account changes, Amex’s statement did not address cardholders, and the research reports no announced changes to cards or rewards.
What the Amex OCC Fine Means for Cardholders
If you carry an Amex card, the $350 million penalty does not come with an announced change to your account or rewards. The orders address the company’s financial crime controls. Here is what you can separate from speculation.
- Cards and rewards. The reporting contains no announced account closures, card changes or rewards cuts linked to the penalty.
- Amex’s statement. The company discussed compliance work and financial guidance without addressing cardholder accounts.
- Customer service. Comptroller Jonathan Gould said Amex would continue serving customers while addressing its money laundering risks. The regulatory action is directed at compliance failures.
- No asset cap. Amex says the orders do not impose a limit on its assets.
- Customer checks. The OCC requires better customer identification and due diligence. This establishes an obligation to improve checks, but does not specify a new review process for your particular account.
- Financial review speculation. Doctor of Credit suggested Amex could conduct more financial reviews and examine manufactured spending more closely. Treat that as the author’s opinion, rather than a confirmed policy announcement.
Want more context on how financial firms police their customers? Our guides to AI fraud detection, PayPal account limits, what Zelle is and the Cash App settlement payment explain the rules you are more likely to meet day to day.
How This Compares With Other Bank AML Penalties
A $350 million fine gets your attention. But you need the restrictions and the underlying issue to compare cases fairly. Amex’s penalty was the OCC’s first civil money penalty against a bank since TD’s October 2024 action. Here is how those cases compare, with Amex’s separate sales-practices settlement included for context.
| Bank | Year | Penalty | Asset cap | Issue |
|---|---|---|---|---|
| American Express National Bank | 2026 | $350 million from the OCC. The Fed imposed no fine | None | Anti-money laundering failures involving about $13 billion in suspected trade-based laundering |
| TD Bank | 2024 | $450 million from the OCC. Total AML penalties exceeded $3.5 billion | $434 billion for its U.S. retail banking operations | Anti-money laundering failures |
| American Express | 2025 | $230 million DOJ settlement | Not stated in the cited settlement reporting | Separate small-business sales-practices conduct from 2014 to 2021 |
The January 2025 settlement is a different case. You should keep its sales-practices allegations separate from the October 2026 findings about detecting and reporting suspicious activity.
Bank Secrecy Act Rules in Plain English
BSA obligations go beyond a single reporting threshold. Bank Secrecy Act and anti-money laundering obligations include identifying customers, monitoring activity and reporting suspicions. The dollar thresholds below come from FinCEN’s guide for money services businesses, so keep that scope in mind as you read them.
| Rule | Threshold | What it requires |
|---|---|---|
| Currency Transaction Report | Cash totalling more than $10,000 by or for one person during one business day | Submit the report within 15 days |
| Funds transfer records | Transfers of $3,000 or more | Record the required information and retain it for five years |
| Money order and traveller’s cheque records | Cash purchases from $3,000 through $10,000, including both endpoints | Document the purchases and retain records for five years |
You see, a recordkeeping requirement and a suspicious activity report serve different purposes. A SAR brings suspected activity to the authorities’ attention. The FinCEN guide uses a $2,000 SAR threshold for money services businesses, but you should not apply that figure to banks, whose thresholds differ.
Amex’s failures concerned detecting, evaluating and reporting suspicious transactions.
Our Take
The penalty matters, but the work required after it matters too. Amex had $308 billion in assets, had already reserved part of the fine and says its 2026 guidance remains intact. If you are assessing what comes next, start with the corrective plans and continuing oversight.
Both regulators require plans within 90 days. The Fed also requires quarterly progress reports, while the OCC requires annual risk assessments and a review of past suspicious activity reporting. Paying the fine does not complete those duties. For your card, no changes have been announced. Keep that fact separate from guesses about future reviews, and watch for actual policy announcements before treating speculation as something that affects your account.
FAQs
Here are answers to the questions you may still have about the penalty and reporting rules.
The OCC penalized American Express National Bank because its anti-money laundering programme failed to meet Bank Secrecy Act obligations. Its findings included deficient customer checks, staffing, training and suspicious activity monitoring involving about $13 billion in suspected trade-based laundering between June 2014 and May 2025. You should keep “suspected” attached to that amount because the findings do not prove that every dollar was criminal proceeds.
No, the Federal Reserve issued a cease-and-desist order without imposing a monetary penalty. The $350 million fine came solely from the OCC and is payable to the U.S. Treasury. If you see both regulators named in a headline, you are reading about coordinated enforcement actions with different requirements.
No changes to your card or rewards have been announced in connection with the fine. Amex’s response does not discuss customer accounts, while the orders require improvements to compliance controls. Suggestions that financial reviews or manufactured spending checks could become more frequent remain commentary, rather than confirmed changes.
Yes, Amex separately agreed to a $230 million DOJ settlement in January 2025 concerning small-business sales practices. That case covered conduct between 2014 and 2021, including allegations about rewards, fees and credit-check disclosures. You should distinguish that settlement from the October 2026 anti-money laundering enforcement actions.
The $3,000 figure concerns recordkeeping in the FinCEN money services business guide, rather than a universal bank reporting trigger. The guide requires records for transfers of at least $3,000 and cash purchases of money orders or traveller’s cheques between $3,000 and $10,000 inclusive. Those records must remain available for five years, and you should not confuse that requirement with a bank SAR threshold.
A Currency Transaction Report is required when cash transactions by or for one person exceed $10,000 within one business day. The FinCEN guide cited here gives a filing deadline of 15 days. You should read this as a cash reporting requirement, separate from the obligations concerning suspicious activity.
The penalty creates a financial cost, but Amex says it does not change its full-year 2026 guidance. The company had reserved part of the amount earlier and does not expect compliance expenses to affect its 2027 guidance. If you are following investor sentiment, shares fell about 2% after hours following the announcement.
