The Office of the Comptroller of the Currency fined American Express $350 million on October 8 for systemic deficiencies in anti-money laundering controls that left $13 billion in suspected trade-based money laundering activity inadequately reported between June 2014 and May 2025.
The enforcement action cites failures in the company's Bank Secrecy Act and AML compliance program spanning a decade. The OCC found that American Express did not file suspicious activity reports for transactions that met reporting thresholds, did not maintain effective transaction monitoring systems, and did not ensure its AML policies were followed. The fine ranks among the largest AML penalties issued to a payments processor in recent years.
American Express operates one of the largest proprietary payment card networks globally, processing more than $1 trillion in transactions annually across corporate and consumer platforms. The company holds a national bank charter and is subject to OCC supervision. Trade-based money laundering involves the misuse of international trade transactions to move value across borders and obscure illicit proceeds.
The $13 billion span covered by the OCC's investigation represents the total volume of transactions the regulator determined should have triggered suspicious activity reports but did not. The OCC did not allege that all $13 billion involved confirmed money laundering; the designation covers transactions meeting reporting criteria under the Bank Secrecy Act. American Express said in response that it has invested significantly in remediation efforts since the OCC's examination began and that it has implemented enhanced transaction monitoring and staffing changes.
The OCC's investigation was conducted jointly with the Federal Reserve. Both agencies issued orders requiring American Express to strengthen its AML program, appoint an independent consultant to audit compliance, and report quarterly on remediation progress. The company was also required to conduct a full review of transactions from the examination period to identify any additional unreported suspicious activity.
Amex penalties for compliance failures have increased in recent years as regulators intensify enforcement on financial crime controls. In 2015, the company paid $100 million to settle separate Bank Secrecy Act violations related to anti-money laundering failures. Deficiencies spanning over a decade led the OCC to classify them as systemic rather than isolated lapses.
The $350 million fine equals 3.5 percent of Amex's annual net income based on 2025 results. The order requiring third-party attestation of remediation efforts will extend OCC oversight of the company's compliance function for at least two years. The document to watch is whether American Express completes its transaction review and files amended suspicious activity reports by the OCC's stated deadline in the first quarter of 2027.
