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.”
American Express’s Form 8-K filed with the SEC claimed that “[a] portion of the civil money penalty was reserved for in prior periods and it does not impact the full-year 2026 guidance.”
It further adds that this is “not anticipated to affect the company’s 2027 guidance.”
This penalty, while not the largest in OCC history, is still a substantial finding, ranking it near the $450 million order against TD Bank in 2024.