The Office of the Comptroller of the Currency announced a $350 million civil penalty and cease-and-desist order against American Express National Bank on Oct. 8. The OCC said the bank’s anti-money-laundering program had gaps in staffing, internal controls, independent testing and training, and did not adequately assess risks in its dominant credit- and charge-card products. The regulator said those failures contributed to delayed identification and reporting of approximately $13 billion in suspected trade-based money laundering over the past decade. The Federal Reserve issued a separate enforcement action against American Express Company the same day. These are regulatory findings about compliance systems; they do not allege that ordinary cardholders were involved in the suspected transactions.