The Office of the Comptroller of the Currency (OCC) on October 8 announced a cease-and-desist order and a $350 million civil money penalty against American Express National Bank over deficiencies in its Bank Secrecy Act and anti-money laundering program. The OCC cited inadequate resources, internal-control gaps, weak testing and training, and risk assessments that did not sufficiently address the bank’s credit and charge card business. It said monitoring and reporting breakdowns meant the bank failed to timely identify, evaluate and sufficiently report approximately $13 billion in suspected trade-based money-laundering activity over the past decade. Separately, the Federal Reserve announced an enforcement action against American Express Company, citing failures to sufficiently detect and report certain suspicious activity and deficiencies in implementation of the company’s enterprise-wide AML program.

Why it matters

  • The OCC’s findings highlight how product-specific risk assessment and monitoring weaknesses can undermine AML controls.
  • The actions involve both the bank and its parent company, with separate federal regulators taking enforcement action.