Current American Express Company (NYSE: AXP) shareholders who have held American Express shares continuously since prior to June 2014 are encouraged to contact Grabar Law Office to learn more about the investigation.

What is Happening? Grabar Law Office is investigating claims on behalf of long-term shareholders of American Express Company (NYSE: AXP) concerning whether certain officers and directors breached fiduciary duties owed to the Company in connection with alleged deficiencies in the Bank Secrecy Act and anti-money laundering compliance program of its banking subsidiary, American Express National Bank.

Why? On October 8, 2026, the Office of the Comptroller of the Currency (“OCC”) issued a Consent Order against American Express National Bank relating to deficiencies in the Bank’s Bank Secrecy Act/anti-money laundering (“BSA/AML”) compliance program. The OCC stated that the deficiencies resulted in violations involving the Bank’s BSA/AML program, suspicious activity reporting, customer due diligence, and customer identification procedures.

According to the OCC, the Bank failed to establish and maintain a reasonably designed BSA/AML compliance program and had systemic internal-control gaps, weaknesses in independent testing, and deficiencies in BSA/AML training. The OCC further identified deficiencies relating to customer due diligence, customer identification procedures, suspicious-activity monitoring and reporting, internal audit, staffing and training.

OCC Identifies Approximately $13 Billion in Suspected Trade-Based Money Laundering Activity

Of particular significance, the OCC found that deficiencies in the Bank’s BSA/AML compliance program contributed to its failure to timely identify, evaluate and sufficiently report suspicious activity associated with suspected trade-based money laundering (“TBML”).

According to the OCC:

From approximately June 2014 through approximately May 2025, American Express National Bank processed approximately $13 billion in suspected TBML activity, including suspicious card charges and repayments of those charges.

The OCC further stated that some of this activity occurred through accounts associated with Bank insiders, and that although the Bank periodically reported suspicious activity during this period, it lacked the internal controls and monitoring capabilities necessary to timely identify and report the full scope of the activity.

The OCC found that these deficiencies resulted in violations of BSA/AML-related regulations and stated that the violations were part of a pattern of misconduct and caused more than a minimal loss to the Bank.

OCC Requires Significant Remedial Measures and Board Oversight

The Consent Order requires American Express National Bank to undertake substantial corrective measures, including, among other things, the Bank must establish a compliance committee to oversee compliance with the Order and provide detailed quarterly reports to the Board concerning required and completed corrective actions.

The Bank also must develop a written action plan addressing the identified deficiencies and establish or enhance programs governing:

• BSA/AML risk assessment;
• customer due diligence and customer identification;
• financial-crimes risk management;
• suspicious-activity identification, investigation and reporting;
• independent BSA/AML testing;
• BSA/AML staffing and expertise;
• employee and director training; and
• monitoring of suspicious activity involving Bank insiders.

The Order further directs the Board to ensure that the required corrective actions are implemented and effective and to hold Bank management and personnel accountable for carrying out their responsibilities under the Order.

What Can Long-Term American Express Shareholders Do?

Grabar Law Office’s investigation is separate from any securities fraud investigation or potential securities class action.

The Firm is investigating whether American Express officers and/or directors failed to exercise appropriate oversight over the Company and its banking subsidiary, failed to ensure adequate BSA/AML controls and compliance systems, or otherwise breached fiduciary duties owed to American Express in connection with the matters described in the OCC Consent Order.

Because the OCC specifically identifies the relevant suspicious-activity period as beginning approximately June 2014, Grabar Law Office is presently interested in speaking with current American Express shareholders who have continuously held AXP shares since prior to June 2014.

Long-term shareholders may be able to pursue claims on behalf of the Company seeking corporate governance reforms, recovery of losses sustained by the Company, the return of compensation or other benefits where appropriate, and other relief for the benefit of American Express and its shareholders at absolutely no cost to them whatsoever.

If you currently own American Express Company (NYSE: AXP) shares and have continuously held those shares since prior to June 2014, you are encouraged to contact Joshua Grabar at jgrabar@grabarlaw.com,  or call 267-507-6085. 

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