American Express enforcement action announced by the Federal Reserve Board on October 8, 2026, addresses the company’s failure to adequately detect and report certain suspicious activity related to money laundering. The Board also identified significant weaknesses in the implementation of the firm’s enterprise-wide anti-money laundering program.
Key Takeaways
- The Federal Reserve cited failures involving the detection and reporting of certain suspicious activity.
- Program implementation deficiencies were particularly evident at American Express Company’s subsidiary national bank.
- The Office of the Comptroller of the Currency issued a separate enforcement action against the bank.
Table of Contents
- American Express enforcement addresses company-wide program
- Separate action against the subsidiary bank
- Conclusion
American Express enforcement addresses company-wide program
The Federal Reserve’s findings extended beyond suspicious-activity detection and reporting to how American Express implemented its anti-money laundering program across the enterprise. The Board singled out the firm’s subsidiary national bank as an area of particular concern.
The Board said its action would help ensure that American Express operates in compliance with all U.S. laws and regulations.
Separate action against the subsidiary bank
The Office of the Comptroller of the Currency, which is the subsidiary national bank’s primary federal regulator, has issued its own enforcement action against the bank. That action is separate from the Federal Reserve’s action against American Express Company.
Conclusion
The announcement identifies compliance failings at both the enterprise and subsidiary-bank levels, with separate enforcement actions addressing the company and the bank.
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