The Office of the Comptroller of the Currency issued a cease and desist order and imposed a USD 350 million civil money penalty on American Express National Bank for deficiencies in its Bank Secrecy Act and anti-money laundering compliance program. The failures included inadequate staffing and expertise, systemic internal control gaps, weak independent testing, and insufficient training for employees and directors. The bank did not tailor its risk assessment to its business, focusing on its relatively narrow demand deposit activities while giving insufficient attention to its dominant credit and charge card products. Deficient customer due diligence and customer identification procedures also contributed to systemic monitoring and reporting breakdowns. As a result, the bank failed to timely identify, evaluate and sufficiently report approximately USD 13 billion of suspected trade based money laundering activity over the past decade. The action was coordinated with a concurrent Federal Reserve Board cease and desist order against American Express Company and American Express Travel Related Services Company. The penalty will be paid to the U.S. Treasury.
U.S. Office of the Comptroller of the Currency fines American Express National Bank USD 350 million over anti-money laundering failures
The Office of the Comptroller of the Currency ordered American Express National Bank to remediate Bank Secrecy Act and anti-money laundering deficiencies and imposed a USD 350 million penalty. Systemic risk assessment, due diligence and monitoring failures prevented the bank from timely identifying, evaluating and sufficiently reporting approximately USD 13 billion of suspected trade based money laundering activity over the past decade.