Yesterday The Office of the Comptroller of the Currency (OCC) announced that American Express would be assesed a $350 million civil penalty and a cease and desist for deficiencies in its Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance program.
“The OCC expects banks of American Express’s size and complexity to devote sufficient resources to ensure compliance with laws and regulations designed to detect and prevent money laundering, which are critical to both economic and national security,” said Comptroller of the Currency Jonathan Gould. “American Express failed to maintain a BSA/AML compliance program properly aligned with the money laundering risks of its operations, which resulted in the bank’s failures to timely identify and report significant missed suspicious activity and to provide important information to law enforcement. Today’s actions will serve to focus American Express on properly addressing such risks as it continues to serve its customers.”
Federal Reserve Board also issued a cease & desist.
In a statement American Express CEO Stephen Squeri stated:
“While we have made meaningful progress, we know there is more work to do,”
In addition he stated:
A portion of the civil money penalty was reserved for in prior periods, and it does not impact full-year 2026 guidance. The consent orders do not impose an asset cap on American Express, and costs associated with addressing the requirements are not anticipated to affect 2027 guidance.
Suspect we will see an uptick in financial reviews and increased scrutiny on manufactured spending on American Express cards as a result of this penalty. Although it’s clear that American Express was aware that a punishment was coming so that uptick in scrutiny may have already occured.
