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United States OCC Bulletins Financial Crime ✓ 14 claims 20 Oct 2026

OCC fines American Express unit $350 million over decade of BSA/AML program failures

The OCC has penalised American Express National Bank $350 million and issued a cease-and-desist order for BSA/AML compliance deficiencies, finding the bank failed to tailor its risk assessment to its dominant card business and missed around $13 billion of suspected trade-based money laundering over the past decade. The Federal Reserve acted concurrently against affiliated entities.

The OCC assessed a $350 million civil money penalty and a cease-and-desist order against American Express National Bank on October 8, 2026.
The bank failed to timely identify, evaluate and sufficiently report approximately $13 billion of suspected trade-based money laundering over the past decade.
The OCC found the risk assessment focused on narrow deposit products and insufficiently on dominant credit and charge card products.
Cited deficiencies included inadequate resources and expertise, systemic internal control gaps, weak independent testing and weak BSA/AML training.
The Federal Reserve issued a concurrent cease-and-desist order against American Express Company and American Express Travel Related Services Company, Inc.

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OCC Bulletins Source document ↗

United States OCC Bulletins Financial Crime ✓ 24 claims 20 Oct 2026

OCC orders Amex bank to rebuild AML program after $13bn suspected laundering flow

The OCC has entered a consent cease-and-desist order against American Express National Bank, finding its anti-money-laundering program was not reasonably designed across risk assessment, customer due diligence, suspicious activity monitoring and training. The order details roughly $13 billion in suspected trade-based money laundering processed over about eleven years, some of it through accounts tied to bank insiders, and imposes a sequence of remediation obligations the board must now deliver.

The Comptroller found the bank processed approximately $13 billion in suspected trade-based money laundering from roughly June 2014 to May 2025, in some instances through accounts associated with bank insiders.
The order cites violations of 12 C.F.R. 21.21, 21.11, and 31 C.F.R. 1020.210(a)(2)(v) and 1020.220(a)(2), with the bank neither admitting nor denying the findings.
The board must appoint a compliance committee within 15 days and submit an action plan within 90 days, and the bank must engage an independent SAR look-back consultant to assess unreported and deficient filings.
The OCC found the bank's risk assessment focused on its narrow deposit products rather than its dominant credit and charge card business, and that internal audit and staffing were inadequate.
The OCC released the bank only from cease-and-desist liability for the described violations and expressly reserved the right to assess civil money penalties or pursue institution-affiliated parties.

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OCC Bulletins Source document ↗

United States OCC Bulletins Financial Crime ✓ 17 claims 20 Oct 2026

OCC fines Bank of America $750 million for BSA failures, its largest penalty ever

The OCC has assessed its largest-ever civil money penalty against Bank of America, N.A., for continued Bank Secrecy Act failures nearly two years after the bank agreed to fix them. The action is coordinated with a FinCEN fine and turns on unmonitored transactions, late suspicious activity reports and a failure to escalate potential money laundering. It matters to anyone managing a BSA/AML program under an existing consent order.

The OCC assessed a $750 million civil money penalty against Bank of America, N.A., which it describes as the largest in OCC history.
The bank remains under a December 2024 cease-and-desist order and, more than a year later, still failed to escalate potentially suspicious activity to investigators.
FinCEN is assessing a separate $1.2 billion fine that credits the OCC's $750 million penalty and requires remedial action.
Cited failures include deficient transaction monitoring across trillions of dollars, late SARs with indicia of money laundering, and processing of potential trade-based money laundering.
The OCC found the BSA Officer and staff lacked sufficient skills and the audit function failed to identify long-standing concerns examiners later uncovered.

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OCC orders Amex bank to rebuild AML program after $13bn suspected laundering flow

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