Bank to Pay OCC $350M After $13B Transferred in Suspected Money Laundering

A national bank settled OCC charges that its deficient AML program allowed the processing of about $13 billion in suspected trade-based money laundering.

The OCC found that from about June 2014 to May 2025, the bank, a major U.S. credit and charge card issuer, processed suspicious card charges and repayments, sometimes through accounts tied to bank insiders. The bank filed some reports but lacked controls to identify and report the full scope.

The OCC cited (i) a risk assessment focused on deposit products rather than card products, (ii) weak customer due diligence and identification, (iii) systemic monitoring breakdowns, (iv) ineffective internal audit testing, and (v) inadequate staffing, expertise, and training.

It found violations of 12 CFR 21.21 ("Procedures for monitoring Bank Secrecy Act (BSA) compliance"), 12 CFR 21.11 ("Suspicious Activity Report"), 31 CFR 1020.210 ("Anti-money laundering program requirements for banks"), and 31 CFR 1020.220 ("Customer identification program requirements for banks"). The action was brought under 12 USC 1818.

The bank agreed to a $350 million civil money penalty and a cease-and-desist order. It must form a board compliance committee, submit an action plan within 90 days, and rebuild its risk assessment, due diligence, monitoring, testing, staffing, and training. An independent consultant must review past activity to decide whether new or amended filings are needed.

In a related Federal Reserve Board cease-and-desist order coordinated with the OCC, the FRB found that the bank's two parent holding companies had enterprise-wide financial crimes risk management deficiencies, including weak transaction monitoring, fraud referrals, and third-party risk assessment. They must submit board oversight and BSA/AML plans within 90 days, and one must submit an OFAC sanctions compliance plan. They may not retain anyone who took part in the misconduct, was formally disciplined for it, and then left or was fired. They must also cooperate with FRB investigations.