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