COOPER BECKWITH, LLCQUALITY · VALUE · SERVICE
Know Your Customer, Know Your Agent

Amex Bank Just Agreed to Pay $350MM for AML Risks It Didn't Know It Had. What Happens When the AI Agents Get Involved?

Know Your Customer, Know Your Agent, bonus paper · October 14, 2026 · John Beckwith, Cooper Beckwith, LLC

Abstract

On October 8, 2026 the OCC found systemic breakdowns in American Express National Bank's suspicious activity monitoring. Its risk assessment watched deposit products while about $13 billion of suspected trade-based money laundering moved through card charges and repayments over eleven years. A BSA and AML program watches what its risk assessment tells it to watch, and AI agents are the next business most risk assessments have not seen.

This bonus paper names five places agents break AML and KYC controls: identity, velocity, intermediation, the inside, and trade. It closes with ten actions, among them putting agents in the BSA and AML risk assessment this cycle, naming the agent in the suspicious activity report, and governing the institution's own AML agents.

Know Your AgentAML and KYCAI risk

The PDF for this paper arrives shortly.

All research

Get the next paper by email

Free. Every new paper reaches subscribers first.