American Express National Bank Agrees to $350 Million OCC AML Penalty

The Office of the Comptroller of the Currency ordered American Express National Bank to pay a $350 million civil money penalty over failures in its Bank Secrecy Act and anti-money laundering programs.

The OCC found that American Express National Bank processed approximately $13 billion in suspected trade-based money laundering activity between June 2014 and May 2025. The activity included suspicious card charges and associated repayments involving credit and charge card products.

Trade-based money laundering involves using trade transactions to move or disguise illicit funds. The enforcement action covers activity that continued for nearly 11 years.

The Federal Reserve separately took enforcement action against American Express over similar failures to meet Bank Secrecy Act and anti-money laundering requirements.

The penalty follows regulatory scrutiny of the bank’s systems for detecting and addressing suspected money laundering activity.