Fed and OCC order Amex to overhaul its anti-money-laundering controls alongside a $350 million fine

A $350 million penalty ^[1] against roughly $13 billion of suspected trade-based money laundering ^[3] works out to about 2.7 cents per dollar ^[17]. Spread over the 11 years from June 2014 to May 2025, the suspected activity averaged around $1.2 billion a year ^[18]. The penalty goes to the U.S. Treasury ^[10].

The money moved through the card book. The OCC described it as "a combination of suspicious card charges and associated repayments of those card charges" ^[3]. By the OCC's account, the bank's risk assessment was weighted toward its deposit accounts ^[5], and its customer due diligence and identification procedures contributed to the monitoring and reporting failures ^[11]. The OCC action stated that weaknesses in the bank's controls around suspicious activity reports were significant and resulted in untimely, missed or incomplete reports, relating both to suspected trade-based money laundering and to other suspicious activity ^[9].

Several of the fixes are staffing questions. The OCC's list of deficiencies covers inadequate resources, including staff without sufficient expertise, along with systemic internal control gaps, weak independent testing and weak training for employees and directors ^[6]. At the holding-company level ^[2], the Fed said New York Fed assessments "identified significant deficiencies in Amex's enterprisewide financial crimes risk management program, including weaknesses in transaction monitoring, fraud referral processes, third-party risk assessment, and financial crimes risk management" ^[8]. The Fed wants remediation plans from the parent companies ^[4].

Stephen Squeri, Amex's chairman and chief executive, presented the spending as already under way. "Over the last few years, we have engaged closely with regulators as we have strengthened our controls and with law enforcement to provide information," he said ^[16]. "We have made and continue to make substantial investments in our people, technology, training, governance, and oversight to fortify how we identify, assess, and respond to evolving financial crimes risk across our business and the industry," he said ^[15].

The look-back decides how large the rest of the bill gets ^[12]. Should the independent reviewer find few reports that ought to have been filed, much of the spending Squeri describes is already in Amex's cost base and the orders cost little beyond the fine. A backlog would stretch the remediation and probably keep the orders open while it is cleared. The third possibility sits outside Amex: examiners at other card lenders could reach the OCC's product-mix conclusion on their own books.

I think the third is the one card and bank compliance teams should budget for, because the OCC tied what it expects to a bank's scale. "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," Comptroller of the Currency Jonathan Gould said ^[7]. These orders concern one issuer. The view that remediation, more than the penalty, sets the cost of this case is wrong if the look-back closes with few additional filings and Amex's disclosures show no step-up in compliance spending.