How much was American Express National Bank fined, and by whom?

The Office of the Comptroller of the Currency assessed a $350 million civil money penalty and issued a cease-and-desist order over deficiencies in the bank's BSA/AML program.

Why does the product mix matter in this case?

The OCC said the bank's risk assessment concentrated on its narrower deposit products and gave insufficient attention to its larger credit and charge card business, so controls were weakest where volume was highest.

OCC fines Amex bank $350m over missed laundering

The OCC says American Express National Bank missed about $13bn of suspected trade-based laundering because its risk model looked at the wrong product.

The OCC's $350 million penalty against American Express National Bank is a transaction-monitoring verdict, not a headline-fee story: regulators say the bank missed roughly $13 billion of suspected trade-based money laundering over a decade because its risk assessment favored deposits over its dominant card business. The Federal Reserve issued a parallel order.

The Ledger Desk October 11, 2026 Updated October 11, 2026 · 3 min read

The OCC issued a $350 million civil money penalty and a cease-and-desist order against American Express National Bank on October 8, 2026.
The OCC says about $13 billion of suspected trade-based money laundering went unreported over roughly ten years.
The core failure was a risk assessment centred on deposit products rather than the much larger credit and charge card book.
The Federal Reserve issued a separate cease-and-desist to American Express and its travel-related services arm.
Card and charge issuers should test whether their BSA/AML risk models weight the products that carry most of the volume.

The OCC has assessed a $350 million civil money penalty against American Express National Bank and issued a cease-and-desist order over deficiencies in its Bank Secrecy Act and anti-money laundering program. The regulator announced the action on October 8, 2026. The Federal Reserve issued a separate order to American Express and its travel-related services arm. The substance matters more than the sum: the OCC says the bank's monitoring was pointed at the wrong product line.

What the OCC says the bank missed

The OCC says systemic breakdowns in suspicious activity monitoring and reporting led the bank to fail to timely identify and report approximately $13 billion of suspected trade-based money laundering over the past decade. That is the regulator's characterisation, and the figure describes suspected activity, not adjudicated crime. The release also lists inadequate resources, staff without sufficient expertise, internal control gaps, weak independent testing and weak BSA/AML training as contributing deficiencies.

The risk assessment looked at the wrong book

According to the OCC, the bank's risk assessment focused on its narrower deposit products, chiefly demand deposit accounts, and gave insufficient attention to its dominant credit and charge card business. For a card issuer this is the central control gap: if the assessment sets monitoring scenarios and staffing, a model weighted toward the small product leaves the high-volume product under-scrutinised. The fix is to size controls to where the money moves.

How this fits the enforcement pattern

Press coverage of the OCC release describes this as the first civil money penalty the agency has imposed on a bank since the $450 million penalty against TD Bank in October 2024. That comparison comes from secondary reporting and should be read as such. The company said it has made progress but has more work to do, and reportedly said part of the penalty was reserved earlier and does not change 2026 guidance. One report says no asset cap was imposed.

What this means for issuers and compliance teams

Any bank or non-bank issuer running a mixed book should check that its BSA/AML risk assessment is weighted by transaction volume and by exposure to cross-border trade flows, not by product count or legacy convention. Independent testing should explicitly challenge that weighting. Compliance leads should also confirm that monitoring staffing scales with the dominant product. Watch for the full orders, which will show the remediation deadlines the OCC and the Federal Reserve require.

How much was American Express National Bank fined, and by whom?: The Office of the Comptroller of the Currency assessed a $350 million civil money penalty and issued a cease-and-desist order over deficiencies in the bank's BSA/AML program.
What did the OCC say went wrong?: The OCC cited inadequate resources and expertise, internal control gaps, weak independent testing and training, and systemic breakdowns in suspicious activity monitoring and reporting. It said these led to a failure to timely identify and report about $13 billion of suspected trade-based money laundering.
Why does the product mix matter in this case?: The OCC said the bank's risk assessment concentrated on its narrower deposit products and gave insufficient attention to its larger credit and charge card business, so controls were weakest where volume was highest.

Amex hit with $350m penalty for AML deficiencies — Finextra
OCC news release 2026-87: OCC assesses $350 million civil money penalty against American Express National Bank — Office of the Comptroller of the Currency