10/14/2026
A BSA/AML program needs to reflect the business your institution actually conducts.
The OCC’s October 8 enforcement action against American Express National Bank is a reminder to look closely at the connection between risk, resources and day-to-day ex*****on.
Katy’s latest article turns the findings into practical questions for community banks and credit unions:
• Does your risk assessment cover the products and services driving activity today?
• Can your team move from an alert to a documented decision without avoidable delays?
• Do independent testing, training and board reporting address your institution’s actual risks?
Use the article to start a focused discussion with your compliance team and leadership.
Read the full article: https://hubs.li/Q04B8-HN0
Seven practical BSA/AML checks for community banks and credit unions, informed by the OCC’s 2026 American Express enforcement action.