CreditMarket noteThursday 8 October 2026, 23:18
American Express money laundering fine: $350m, and no asset cap
The American Express money laundering fine is $350m: regulators found its bank missed about $13bn of suspect activity over a decade, from 2014 to 2025.
By The Notebook Desk
The American Express money laundering fine is $350m. The Office of the Comptroller of the Currency, which supervises national banks, fined American Express National Bank on Thursday for failures in its anti-money laundering programme, which US banks must run under the Bank Secrecy Act (BSA). It also ordered the bank to fix them.
The size of what was missed stands out. From about June 2014 to about May 2025, the bank processed about $13bn of suspected trade-based money laundering, the OCC’s order says. That included suspicious card charges and the repayments of those charges, “in certain instances through accounts associated with Bank insiders”. The bank reported some of it, but it lacked the controls to see “the full scope of this activity”.
The Federal Reserve took its own action the same day. It issued an order to cease and desist against the parent company, American Express Company, and its unit American Express Travel Related Services. The Fed’s order carries no fine. American Express neither admits nor denies the findings.
What the regulators found
Trade-based money laundering hides criminal money inside what look like ordinary payments for goods and services.
The OCC says the bank looked for risk in the wrong place. Its risk assessment “focused on the risks in the Bank’s relatively narrow demand deposit account products”, meaning its current accounts, and “insufficiently on the risks in its more dominant credit and charge card products”. The OCC also found gaps in how the bank checked who its customers were, “systemic breakdowns” in monitoring and reporting suspicious activity, weak internal audit, and too few staff with the right skills.
“American Express failed to maintain a BSA/AML compliance program properly aligned with the money laundering risks of its operations,” said Jonathan Gould, the Comptroller of the Currency.
The Fed’s order says examiners at the New York Fed found “significant deficiencies” across the group, including weaknesses in transaction monitoring, fraud referrals and the assessment of risk from third parties.
What American Express must do
The bank must hire an independent consultant to look back over its past suspicious activity monitoring, and decide whether reports that should have gone to the authorities were missed. Within 90 days, the board of the parent company must send the New York Fed a plan for overseeing the clean-up, including how it will hold senior managers to account.
What it costs American Express
Not much, on the company’s own account. Part of the penalty was set aside in earlier periods, and it does not change the forecast for 2026, American Express said in a filing. It expects the cost of meeting the orders not to affect its forecast for 2027 either. The same filing lists “potential additional fines, penalties, or judgments” among the risks to its outlook.
The fine equals about 3% of the company’s net income of $10.83bn in 2025, by our calculation from its filings with the SEC.
The most important line in the filing is that the orders “do not impose an asset cap”. An asset cap stops a bank from growing its balance sheet. The OCC put one on TD Bank in 2024, alongside a $450m fine for failures of the same kind. Wells Fargo lived under a Fed asset cap from 2018 until June 2025. American Express can keep growing its loans and card spending while it fixes its controls.
What to watch next
American Express reports its third-quarter results on 23 October, with a call at 8:30am New York time, the company has said. The cost of compliance and any word on other investigations will be the things to listen for.
The look-back matters too. If the consultant finds more suspicious activity that should have been reported, the bank will have to file the reports, and the story may not end with this fine.
Disclosure
This is analysis and opinion, not investment advice.