American Express bank to pay $350 million OCC penalty over financial crimes compliance
American Express says its national bank agreed to a $350 million civil money penalty from the OCC, and the parent company agreed to a Federal Reserve order. Both orders resolve regulator reviews of its financial crimes compliance program.
American Express said in a filing with the US Securities and Exchange Commission (SEC) that, on October 8, 2026, its bank subsidiary, American Express National Bank, consented to an order issued by the Office of the Comptroller of the Currency (OCC). The bank also agreed to pay a civil money penalty of $350 million to the OCC.
On the same date, American Express Company and American Express Travel Related Services Company, Inc. consented to an order issued by the Board of Governors of the Federal Reserve System. According to the filing, the orders resolve previously disclosed reviews by the banking regulators of certain aspects of the company's financial crimes compliance program.
The filing states that the consent orders do not impose an asset cap on the company. It also says part of the penalty was reserved for in earlier periods and that the penalty does not affect its full-year 2026 guidance. It says the costs of meeting the orders' requirements are not expected to affect its 2027 guidance.
This account is based on the company's filing. The OCC's own announcement could not be accessed when this draft was written, so the regulator's specific findings and the full requirements of each order are not described here.
Why it matters to AML professionals
A consent order usually requires a bank to fix its compliance program under the regulator's supervision, which means more work for monitoring, KYC and investigations teams. When an enforcement case targets the financial crimes program as a whole, every part of it, from customer due diligence to suspicious activity reporting, is likely to be reviewed.
Red flags in this case
- Alerts that stay open well past internal deadlines because of a growing backlog
- Customer risk ratings that are not updated after the customer's activity changes
- Suspicious activity reports filed late or with thin narratives
- Monitoring rules that have not been tuned or validated for a long time
If this landed in your queue
- Check whether your alert and case backlog is within the timelines set in your procedures, and escalate if it is not
- Make sure every case decision has a written rationale and the evidence saved in the case file
- Flag customers whose activity no longer matches their risk rating or stated profile for a periodic review
- Know your escalation path to the BSA/AML officer for issues that look systemic rather than one-off
Key terms
- Consent order
- A formal enforcement order the institution agrees to, which sets out actions it must take under the regulator's supervision.
- Civil money penalty
- A fine imposed by a regulator for violations, without a criminal charge.
- Asset cap
- A regulator-imposed limit on how large an institution's balance sheet can grow until it fixes identified problems.
Interview angle
If your bank entered a consent order covering its financial crimes program, how would your day-to-day work change?
Explain that remediation brings tighter deadlines, lookback reviews and closer quality checks, and show how you would keep your documentation complete and escalate issues early.
Sources
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