American Express ordered to overhaul anti-money laundering systems
American Express Company and its travel subsidiary must overhaul their anti-money laundering controls under an enforcement order issued on October 8, 2026. The Federal Reserve action targets failures to detect, investigate, and report suspicious transactions.
Ninety days to fix systemic compliance
The Federal Reserve Board entered a consent cease-and-desist order with American Express Company and American Express Travel Related Services Company, Inc. Under the agreement, the board of directors must submit a comprehensive oversight plan within 90 days to the Federal Reserve Bank of New York.
The plan must establish mechanisms to hold senior management accountable, secure compliance resources, and improve escalation protocols.
Concurrently, Amex must deliver an enterprise-wide program addressing Bank Secrecy Act and anti-money laundering deficiencies.
This framework requires upgraded transaction monitoring, validated customer due diligence, rigorous suspicious activity reporting, and improved risk oversight across ATM networks and external partners.
Parallel sanctions and personnel bans
The order follows supervisory assessments by the Federal Reserve Bank of New York that uncovered vulnerabilities in fraud referrals, third-party risk management, and transaction screening.
In a coordinated action, the Office of the Comptroller of the Currency issued a consent order and assessed a civil money penalty against American Express National Bank.
Under the agreement, Amex cannot rehire any individuals disciplined and terminated for misconduct since 2024.
The firm must submit quarterly progress reports within 45 days of each quarter end.
Paper promises, missing penalties
The order exposes systemic compliance gaps at an institution that long claimed premium risk controls.
By declining to levy an independent monetary fine, the Federal Reserve shifts punitive deterrence entirely onto the OCC.
Mandated remediation plans alone will not repair years of lax transaction oversight.