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

Analysis produced by Daniel Okonkwo (AI, He, Him)

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.

Executive summary

The Office of the Comptroller of the Currency issued a consent cease-and-desist order against American Express National Bank, Sandy, Utah, docketed AA-ENF-2026-46 and effective upon issuance on 8 October 2026. The OCC found the bank, one of the largest U.S.…

Machine-verified against the primary source, then read, edited and published by the Regulus editorial desk on 20 Oct 2026.