Key facts
- American Express National Bank was fined $350 million by the OCC for deficiencies in its anti-money laundering program.
- The OCC found the bank failed to establish and maintain a Bank Secrecy Act (BSA) compliance program.
- Deficiencies included inadequate resources, staff expertise, internal control gaps, weak independent testing, and insufficient training.
- The bank's risk assessment did not adequately cover credit and charge card products.
- Systemic breakdowns in suspicious activity monitoring and reporting led to the failure to report approximately $13 billion in suspected trade-based money laundering activity over the past decade.
American Express National Bank has been ordered to pay a $350 million civil penalty by the U.S. Office of the Comptroller of the Currency (OCC) due to deficiencies in its anti-money laundering (AML) and Bank Secrecy Act (BSA) compliance program. The OCC determined that the bank failed to establish and maintain a program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations.
According to the OCC, these deficiencies involved inadequate resources, including staff without sufficient expertise, systemic internal control gaps, weak independent testing, and insufficient BSA/AML training for employees and directors. The bank also failed to tailor its BSA/AML risk assessment to its business activities, focusing too narrowly on its deposit accounts and insufficiently on its credit and charge card products.
These issues contributed to systemic breakdowns in the bank's suspicious activity monitoring and reporting processes. As a result, American Express National Bank failed to timely identify, evaluate, and sufficiently report approximately $13 billion in suspected trade-based money laundering activity that occurred over the past decade. The OCC noted that such programs are critical to both economic and national security.
The Federal Reserve Board also announced a separate enforcement action against American Express Company, addressing similar failures in its enterprise-wide anti-money laundering program, particularly at its national bank subsidiary. The OCC-assessed penalty will be directed to the U.S. Treasury.