American Express National Bank processed approximately $13 billion in suspected trade-based money laundering (TBML) between June 2014 and May 2025, including through accounts associated with bank insiders, the Office of the Comptroller of the Currency (OCC) found.

The OCC and American Express National Bank have agreed to a consent order that will see American Express pay $350 million for failure to maintain an effective Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) program.

Additionally, American Express was the target of a Federal Reserve enforcement action for a similar failure to meet BSA/AML requirements.

The OCC consent order alleges that the behavior ran from approximately June 2014 to May 2025 and saw the bank process “approximately $13 billion in suspected TBML activity, including a combination of suspicious card charges and associated repayments of those card charges, and including in certain instances through accounts associated with bank insiders.”

TBML is a form of money laundering that focuses on manipulating trade transactions, with manipulated invoices, for example, to help legitimize “dirty” funds.

In this case, it seems related to how the American Express credit cards were used.

The Federal Reserve enforcement action specifically bars American Express from “directly or indirectly retaining any individual as an officer, employee, agent, consultant, or contractor of the firm or any subsidiary or affiliate thereof who, based on the investigative record compiled by the firm during the period 2024 to the present: (i) participated in the misconduct underlying this order; (ii) was subjected to formal disciplinary action as a result of the firm’s internal disciplinary or performance reviews in connection with the misconduct underlying this order; and (iii) either separated from the firm or had his or her employment legally terminated in connection with the misconduct underlying this order.”

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