OCC Fines American Express Bank $350 Million Over AML Lapses Tied to $13 Billion of Suspect Activity

The Office of the Comptroller of the Currency on Thursday, Oct. 8, ordered American Express National Bank to pay a $350 million civil money penalty and issued a cease-and-desist order over deficiencies in its Bank Secrecy Act and anti-money-laundering program. The OCC said the bank failed to timely identify, evaluate and report roughly $13 billion of suspected trade-based money laundering activity, which Banking Dive reports took place between June 2014 and May 2025. The Federal Reserve issued its own enforcement action against the parent company.

AXP moved quickly to frame the hit as contained. In an SEC filing, the company said the penalty does not affect its full-year 2026 guidance, that costs from the orders are not expected to affect its 2027 guidance, and that the consent orders impose no asset cap. The filing said part of the penalty had already been reserved in prior periods, and the company had flagged a possible AML enforcement action in its filings months earlier. Under the orders, the bank must submit an action plan within 90 days and commission a third-party review of past suspicious activity, according to Banking Dive. CEO Stephen Squeri said: "While we have made meaningful progress, we know there is more work to do."

The market read it as a manageable cost. Shares fell about 2% in after-hours trading Thursday and were down about 0.5% at $306.60 in late-morning trading Friday, per SentiSense data. Separately, BMO initiated coverage on Friday at Outperform with a $380 target, citing premium-card growth, in a note that does not appear to be a response to the penalty.

What to watch: the 90-day action plan, any findings from the third-party lookback that could add remediation costs, and whether the absence of an asset cap keeps this a one-time charge rather than the kind of growth constraint other banks have faced under AML orders.