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Bank enforcement

OCC imposes $350 million penalty on American Express National Bank

American Express National Bank, based in Sandy, Utah, received a $350 million penalty and a corrective order on October 8. The OCC cited failures in its anti-money-laundering controls and reporting of suspected activity. [1]

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The regulator’s findings

The Office of the Comptroller of the Currency said the bank’s monitoring broke down over the past decade, leaving approximately $13 billion in suspected trade-based money-laundering activity insufficiently identified, evaluated and reported. The agency’s finding concerns suspected activity; that figure is not a finding that $13 billion was proven to have been laundered. [1]

The OCC said the bank concentrated its risk assessment on its relatively narrow deposit business and paid insufficient attention to its larger credit and charge-card operations. It also identified weaknesses in staffing, internal controls, independent testing and training. [1]

Orders, corrective work and the company’s response

The penalty order requires payment of $350 million upon execution. A separate requires the bank to submit a corrective action plan within 90 days for supervisory review, covering the identified compliance deficiencies. [2][3]

The Federal Reserve announced a concurrent action against American Express Company, identifying shortcomings in its enterprise-wide anti-money-laundering program, especially at the national-bank subsidiary. [4]

Reuters reported that American Express did not admit or deny the regulators’ findings. The company said it was committed to addressing the concerns; CEO Stephen Squeri said the penalty and compliance costs were not expected to affect its 2026 or 2027 guidance. That is the company’s forecast. [5]

Sources

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