OCC Assesses $350 Million Civil Money Penalty Against American Express — 2026-10-08

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced a cease-and-desist order and a $350 million civil money penalty against American Express National Bank, Sandy, Utah (bank), for deficiencies in the bank’s Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance program. The OCC determined that the bank failed to establish and maintain a BSA/AML compliance program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations. Deficiencies in the Bank’s BSA/AML program involved inadequate resources, including staff without sufficient expertise, systemic internal control gaps, weak independent testing, and weak BSA/AML training for employees and directors. The OCC found that the bank failed to tailor its BSA/AML risk assessment to its business activities. The bank focused on the risks in its relatively narrow demand deposit account products and services and insufficiently on the risks in its more dominant credit and charge card products.