American Express's bank must pay $350 million over late, incomplete or missing reports

The Office of the Comptroller of the Currency on Thursday fined American Express National Bank $350 million after the bank failed to identify, evaluate and sufficiently report about $13 billion of suspected money laundering in time.

The penalty is civil, the money goes to the U.S. Treasury, and payment is due now that the bank has signed the order. The OCC also ordered the bank to fix the program.

Where the reports broke down

From about June 2014 to May 2025, the bank processed about $13 billion of suspected trade-based money laundering, the OCC's order says. That activity included suspicious card charges and the repayments of those charges. In some cases it ran through accounts tied to bank insiders, and the order does not name them.

Trade-based money laundering is illicit money disguised as ordinary business. The OCC said breakdowns in monitoring meant the bank did not identify, evaluate and report enough of the activity in time. That $13 billion is suspected activity whose reports were late, incomplete or missing.

The OCC said the bank focused on a relatively narrow deposit-account operation and not enough on the credit and charge cards that are the larger part of the bank. It also found too few staff with the right skills, gaps in internal controls, and weak testing and training.

Banks must keep a program under the Bank Secrecy Act, the federal law that requires them to spot and report suspected money laundering.

"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," Comptroller of the Currency Jonathan Gould said.

A fine, but no limit on growth

At 4:30 p.m. Eastern time, the Federal Reserve issued its own order against the parent, American Express Company, and American Express Travel Related Services, a second bank holding company the Fed supervises. The Fed said the parent's anti-money-laundering program had significant gaps, especially at the bank. It ordered a fix and assessed no fine of its own.

Within 90 days the parent must send the Fed a board plan and a written plan to improve the company-wide program. Each plan must include deadlines for the work, and neither takes effect until the Reserve Bank approves it.

The Fed's order sets no cap on the company's assets. American Express said the OCC order does not either. A cap limits how large a bank can get while it fixes its controls. In October 2024 the OCC fined TD Bank's U.S. subsidiaries $450 million and did impose that limit.

The Fed's order leaves other federal and state agencies free to act. The OCC's penalty order does not resolve any action by the Justice Department.

The full fine equals about 11% of the $3.1 billion American Express earned in the second quarter. The company said a portion was already reserved, without saying how much, and that full-year 2026 guidance still stands. The cost of the fixes, it said, is not expected to change the 2027 outlook.

Shares closed the regular session at $308.10, up 1.3%, before the Fed's 4:30 p.m. release. Yahoo Finance reported at 5:19 p.m. Eastern time that the shares had fallen 2% in extended trading.

American Express reports third-quarter results on Friday, October 23. That is the first scheduled look at what the penalty, beyond the amount already reserved, and the cost of the fixes, do to profit.