The enforcement action highlights a decade-long failure to properly evaluate and report high-risk activity. According to the OCC, American Express concentrated its compliance efforts on narrow deposit products while neglecting its far more significant credit card business. This oversight left the institution vulnerable to financial crime, as the bank struggled with both customer due diligence and basic identification programs.

Comptroller of the Currency Jonathan Gould emphasized that institutions of this scale must prioritize resources to uphold national security standards. The bank neither admitted nor denied the findings. By failing to maintain robust oversight, the firm allowed billions to flow through its systems without the required scrutiny, prompting the heavy financial sanction from federal authorities.