The Office of the Comptroller of the Currency (OCC), the main banking regulator in the US, has issued a $350m civil money penalty against American Express National Bank for deficiencies in its anti-money laundering (AML) and bank secrecy act (BSA) processes.
The Office of the Comptroller of the Currency (OCC), the main banking regulator in the US, has issued a $350m civil money penalty against American Express National Bank for deficiencies in its anti-money laundering (AML) and bank secrecy act (BSA) processes.
In context
- Topic: Banca y Fintech — Banca digital, pagos, open banking y regulación financiera.
- Source: Finextra
- Published: 09/10/2026
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Why it matters
What I see behind almost every digital banking story is the same tension: the front end is modern and the core is still a system that has been running for twenty years and nobody dares touch. The distance between those two layers explains most of the projects that slip.
My view here is shaped by the Panamanian market: regulation changes, standards arrive with a deadline, and the operation has to keep invoicing while it adapts. The useful question is not whether it suits you, it is how much time there is to comply.
What usually goes wrong
The mistake that repeats is testing only the happy path. It gets validated that the transaction works, not that the reversal works, that duplicates are caught, that a power cut mid-operation leaves everything consistent. Those cases are ninety per cent of the real work and ten per cent of the testing.
What to watch
- What happens to cost per transaction at real volume, which is where the business is decided.
- How daily reconciliation is left, which is where the cases nobody modelled show up.
- What the local regulator requires and by when, because the deadline is usually the real constraint.
How I read this entry
If this came into an institution, I would look at reconciliation first. Everything new in payments looks fine until the day has to balance, and that is when the cases nobody modelled appear: reversals, duplicates, half-completed transactions. That boring work decides whether the product is sustainable.
This entry is an excerpt from the original source, selected by the site radar. The commentary above is the site's own and does not belong to the cited publisher.
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Living through this in your own team?
Open the chat and tell me how you're handling it. I'm interested in comparing notes.
