American Express fined $350 million: its risk assessment looked at current accounts, while $13 billion of suspicious transactions went through its cards
9 October 2026, 18:20
8 October. The OCC, the federal authority that supervises US national banks, fines American Express National Bank $350 million, payable to the Treasury, and together with the Federal Reserve requires the group to rebuild its anti-money laundering system. According to the order, from June 2014 to May 2025 about $13 billion of transactions suspected of trade-based money laundering went through the bank, counting both the card charges and the payments that settled them, in some cases through accounts "associated with Bank insiders", that is, people inside the bank. Some of them were reported from time to time; the full picture, the OCC writes, was missed. The bank neither admits nor denies.
Who did the laundering, the order does not say. A scheme of this kind was described in August 2025 by FinCEN, the US Treasury's anti-money laundering unit, for the Chinese networks that launder the Mexican cartels' money: straw buyers or complicit shopkeepers buy electronics and luxury goods with credit cards that the network then pays off; the goods are resold in the United States or shipped abroad. The money changes country without crossing the border: the goods cross it instead.
The first failing listed by the OCC is the risk assessment: it focused on the bank's "relatively narrow" current accounts and "insufficiently" on cards, by far its main business. It is the supermarket that puts the camera over the sweets shelf, leaves the phone shelf in the dark, and is then surprised by the shortfall.
A control is worth what it looks at, and if it looks where little money passes it reassures without protecting. It happens in companies too, when expense claims are checked to the cent and the largest bank transfers are signed off at a glance.
When a small Italian business opens an account, it is asked every question: who the beneficial owner is, what the relationship is for. They are set out in Article 18 of Legislative Decree 231 of 2007, which also requires the relationship to be monitored for its whole duration. That is the part the OCC faults American Express for: understanding "the nature and purpose" of customer relationships, and keeping watch over them over time. At the bank counter, it seems, the questionnaire is stricter with those who move less money.
So the question, for the OCC: its examiners have been examining the bank all year round since it became a national bank in 2018. When did they first see a risk assessment that looked at current accounts and not at cards?
American Express told investors that part of the penalty had already been reserved for in prior periods.
The fine, American Express had budgeted for. The suspicious transactions, only in part.
This article was prompted by a news item published in American Banker on 8 October 2026.