OCC orders American Express National Bank to fix AML controls

The Tip Desk · November 4, 2026 · 1 min read

American Express National Bank must strengthen board oversight, submit a remediation plan and commission an independent suspicious activity review.

American Express National Bank (AXP) must overhaul its Bank Secrecy Act and anti-money laundering controls under an Oct. 8, 2026, consent order from the Office of the Comptroller of the Currency.

The OCC found systemic weaknesses in customer due diligence, customer identification and suspicious activity reporting; the bank neither admits nor denies the findings. The regulator found that the bank processed approximately $13 billion in suspected trade-based money laundering activity from approximately June 2014 through May 2025 without timely identifying and reporting its full scope.

The bank's board must appoint a compliance committee within 15 days to oversee compliance, and the bank must submit a remediation plan within 90 days for the OCC's prior written determination of no supervisory objection. The board must ensure corrective actions are implemented, verify their effectiveness and hold management and personnel accountable.

The bank must engage an independent consultant, subject to OCC non-objection, to review past suspicious activity monitoring and reporting and determine whether additional or corrected suspicious activity reports are needed. It must also establish risk-based transaction limits and controls to identify and monitor suspicious insider activity.