Federal Reserve issues AML cease and desist order against American Express
On October 8, 2026, the Federal Reserve Board announced a consent order against American Express Company over failures to detect, investigate and report certain suspicious activity. The OCC took a separate action against the company's national bank.
On October 8, 2026, the Board of Governors of the Federal Reserve System announced an enforcement action against American Express Company. The action is a cease and desist order issued on consent, meaning the firm agreed to it. It names American Express Company and American Express Travel Related Services Company, Inc. The firm neither admitted nor denied the allegations.
According to the Board, the action addresses the firm's failure to timely and sufficiently detect, investigate and report certain suspicious activity. Supervisory assessments by the Federal Reserve Bank of New York found significant deficiencies in the firm's enterprise-wide financial crimes risk management program, including weaknesses in transaction monitoring, fraud referral processes and third-party risk assessment. The Board says the deficiencies were particularly in how the program was implemented at the firm's subsidiary national bank.
The order requires the American Express board to submit, within 90 days, a written plan on senior management accountability, remediation resources, the Bank Secrecy Act/anti-money laundering (BSA/AML) program, and escalation and reporting. Within the same 90 days, the firm must submit a plan to improve its enterprise-wide BSA/AML program, covering areas such as transaction monitoring, customer due diligence, suspicious activity reporting and oversight of network, ATM and third-party partners. Travel Related Services must also submit a plan on OFAC (US sanctions) compliance, covering risk assessment, training, and screening policies and procedures. The board must send written progress reports each quarter.
The Office of the Comptroller of the Currency (OCC), the bank's primary federal regulator, issued a separate consent cease-and-desist order and civil money penalty against the bank. The Federal Reserve's order does not state the amount of that penalty.
Why it matters to AML professionals
Regulators look at whether suspicious activity is caught and reported on time, not only whether a monitoring system exists. Weak links between fraud teams and AML teams, and weak oversight of third-party partners, can lead to missed or late suspicious activity reports. AML professionals should know how fraud referrals reach their queue and how partner activity is monitored.
Red flags in this case
- Fraud cases that are closed by the fraud team without a referral to the AML or investigations team
- Monitoring alerts that sit open past internal deadlines before a decision to file or close
- Activity that runs through third-party partners or network channels with no independent risk review
- Repeated customer complaints or fraud claims on one account that never trigger an AML review
If this landed in your queue
- Pull the full alert and account history, including any fraud claims or fraud team notes linked to the customer
- Check whether the activity came through a third-party partner or network channel, and what due diligence is held on that channel
- Confirm the date the activity was first detected so that any suspicious activity report is filed within regulatory timelines
- Escalate to the compliance officer if past fraud cases on the account were never reviewed for suspicious activity reporting
What control failed
Suspicious activity reporting. The Federal Reserve says the firm failed to timely and sufficiently detect, investigate and report certain suspicious activity, with weaknesses in transaction monitoring, fraud referral processes and third-party risk assessment.
Key terms
- Cease and desist order
- A regulator's order requiring a firm to stop unsafe practices and fix them, often with deadlines for written plans.
- Issued on consent
- The firm agrees to the order without going to a hearing, usually without admitting or denying the findings.
- Fraud referral process
- The steps a firm uses to pass fraud cases to the AML team so they can be reviewed for suspicious activity reporting.
Interview angle
How should a fraud team and an AML team work together on the same customer case?
A strong candidate explains that fraud cases can also be money laundering cases, so there should be a clear referral route, shared case notes and a decision on whether a suspicious activity report is needed. Mention timelines and documentation.
Sources
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