OCC Hits American Express with $350M Penalty for BSA/AML Failures
The OCC issued a cease-and-desist order and a $350 million civil money penalty against American Express National Bank for deficiencies in its BSA/AML compliance program. This is a high-profile enforcement action signaling that regulators are actively scrutinizing AML program adequacy at large financial institutions. Compliance officers should treat this as a benchmark for the level of rigor expected in BSA/AML controls.
What to do
- Review your institution's BSA/AML program against OCC expectations — including transaction monitoring, suspicious activity reporting, and governance — and document any gaps identified for remediation.
Who this affects
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Source
Read the official publicationThis radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.