OCC Fines American Express $350 Million Over AML Failures Tied to $13 Billion in Suspected Transactions

American Express faces a $350 million OCC penalty over anti-money laundering failures involving approximately $13 billion in suspected activity.

The U.S. Office of the Comptroller of the Currency (OCC) has imposed a $350 million civil money penalty on American Express National Bank after identifying systemic deficiencies in its anti-money laundering (AML) compliance program, including failures involving approximately $13 billion in suspected trade-based money laundering activity over the past decade.

Coin Bureau reported the enforcement action in a post on X. According to the OCC, the bank failed to identify, evaluate and sufficiently report suspicious activity in a timely manner, raising concerns about its ability to detect potentially illicit financial transactions and provide relevant information to law enforcement.

OCC Cites Weak Controls and Risk Assessments

The OCC identified several shortcomings in American Express National Bank's compliance framework, including inadequate staffing resources, employees without sufficient expertise, systemic internal control gaps and weaknesses in independent testing. The regulator also cited insufficient anti-money laundering training for employees and directors.

Risk assessment procedures were another area of concern. According to the OCC, the bank did not adequately tailor its assessment of money markets laundering risks to its business activities. It focused more heavily on its relatively narrow demand deposit account products and services while giving insufficient attention to the risks associated with its more dominant credit and charge card operations.

The regulator also identified weaknesses in customer due diligence and customer identification procedures. These deficiencies contributed to breakdowns in suspicious-activity monitoring and reporting, preventing the bank from properly identifying, evaluating and reporting approximately $13 billion in suspected trade-based money laundering activity over the past decade.

Federal Reserve Announces Separate Enforcement Action

The OCC's penalty was accompanied by a separate enforcement action from the Board of Governors of the Federal Reserve System. The Federal Reserve issued a cease-and-desist order against American Express Company and American Express Travel Related Services Company, Inc., two entities named in connection with the broader compliance concerns.

The OCC also issued a cease-and-desist order against American Express National Bank. The actions address deficiencies in the bank's compliance with the Bank Secrecy Act (BSA) and related anti-money laundering regulations, which require financial institutions to maintain appropriate systems for identifying and reporting suspicious transactions.

The $350 million civil money penalty will be directed to the U.S. Treasury, according to the OCC. The regulator said banks of American Express's size and operational complexity are expected to dedicate sufficient resources to meeting legal requirements designed to detect and prevent money laundering.

Scope of the Reported Failures

The approximately $13 billion figure refers to suspected trade-based money laundering activity that the bank failed to identify, evaluate and sufficiently report in a timely manner. It does not, by itself, establish that every transaction involved confirmed financial money laundering. The OCC's findings center on deficiencies in the bank's monitoring, risk assessment and reporting systems.

The enforcement actions place the bank's internal controls, staffing, risk management and suspicious-activity reporting processes at the center of the regulatory findings. The OCC's stated concerns extend beyond individual transactions to the systems intended to identify potential financial crime across American Express National Bank's operations.

Writer: Victoria Hale
Technology & Blockchain Writer

Victoria Hale writes about blockchain technology, digital infrastructure, and the intersection of emerging technologies with finance. Her articles explore how new protocols and systems are shaping the evolving digital economy.

She prioritises clarity and accuracy when explaining technical developments to a general audience.

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