U.S. bank regulators fine American Express $350 million after concluding the firm’s anti-money laundering (AML) program is insufficient. The penalties are linked to findings that suspicious activity may not have been identified or escalated as required.

Reports say the regulators identify “systemic” or “significant” deficiencies in how the AML program is implemented across the company, particularly at American Express’s banking subsidiary, American Express National Bank. The Financial Times reports that regulator findings include roughly $13 billion in suspicious transactions that were not reported, while BNN Bloomberg cites the possibility of billions in missed suspicious activity.

Across the outlets, the central point is the same: the regulators’ assessment focuses on gaps in the enterprise-wide AML controls and their execution, not on a specific, singular incident. The outlets differ mainly in how they describe the scope of the failures and the figures cited for unreported or potentially missed suspicious transactions.