OCC Assesses $350 Million Civil Money Penalty Against American Express

When transaction monitoring rules are tuned, alerts are dismissed, or suspicious activity reports are withheld, those are decisions—and each one carries money laundering risk that regulators will reconstruct after the fact. The OCC's order reflects a familiar pattern: AML programs that operate as interpretive routines rather than recorded judgments, leaving no artifact to prove who decided what on which evidence when the examiner arrives. Decision Governance closes that gap by treating every control decision as a system-of-record event, ensuring that the BSA Officer's rationale for clearing a high-risk alert is as durable and examinable as the alert itself. Decisions deserve engineering rigor, and BSA compliance is decided one transaction at a time.