The OCC announced a cease-and-desist order and $350 million civil money penalty against American Express National Bank (Sandy, Utah) for BSA/AML program deficiencies, including inadequate risk assessment tailored to card products, weak CDD/CIP, suspicious-activity monitoring breakdowns, and insufficient staff expertise and training.
From approximately June 2014 to May 2025 the bank processed roughly $13 billion in suspected trade-based money laundering activity involving suspicious card charges and repayments, including in certain instances accounts associated with bank insiders. The OCC coordinated with a concurrent Federal Reserve enforcement action against American Express Company and American Express Travel Related Services Company.