Fed takes enforcement action against American Express over suspicious-activity reporting

Victoria Shinder12 October 2026, 08:282 min read

The Federal Reserve Board announced on 8 October an enforcement action against American Express Company, addressing "among other things" the firm's failure to sufficiently detect and report certain suspicious activity related to money laundering.

What the Board found. Beyond the reporting failures, the Fed says it identified significant deficiencies in how American Express implemented its enterprise-wide anti-money-laundering programme, "in particular at the firm's subsidiary national bank". The Office of the Comptroller of the Currency, which is the primary federal regulator of that national bank, has issued a separate enforcement action against the bank itself.

Why two regulators. In the U.S. system, the Federal Reserve supervises bank holding companies — here American Express Company at the group level — while the OCC supervises nationally chartered banks. An AML failure that runs through a group's bank subsidiary therefore typically draws parallel actions: one aimed at the parent's enterprise-wide programme and governance, one at the bank's own controls. The Fed's statement says its action "will help ensure that the firm operates in compliance with all U.S. laws and regulations".

What the release does not say. It gives no civil money penalty, no timeline for remediation and no detail on the type or volume of suspicious activity that went unreported. The announcement text does not describe the terms of the order. Whether a fine follows, here or from the OCC, is not stated in the Fed's announcement.

Why it matters for payments. American Express is both a card network and a lender, with a nationally chartered bank inside the group. Suspicious-activity reporting is the core obligation under U.S. anti-money-laundering rules: institutions must file reports with FinCEN when they detect transactions that may involve illicit funds. A finding that detection and reporting fell short — and that the problem was programme-wide rather than isolated — points to remediation of the whole programme rather than a single fix, which is what the Fed's wording signals.

The Fed also announced an enforcement action against a smaller institution, Ontario Bancorporation, on 2 October.

Source: Federal Reserve Board, 8 October 2026 — https://www.federalreserve.gov/newsevents/pressreleases/enforcement20261008a.htm