UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
FILED by CF D,C.
AUG 6, 2007
CLERK U.S. OIST. CT.
S.D. OF FLA.' MIAMI
UNITED STATES OF AMERICA,
AMERICAN EXPRESS BANK
THE UNITED STATES OF AMERICA, ACTING THROUGH ITS ATTORNEYS,
At all times material to this Information:
Defendant AMERICAN EXPRESS BANK INTERNATIONAL is an Edge Act
Corporation, headquartered in Miami, Florida.
Defendant AMERICAN EXPRESS BANK INTERNATIONAL is subject to
oversight and regulation by the Board of Governors of the Federal Reserve, by and through the
Federal Reserve Bank of Atlanta (Federal Reserve).
The Bank Secrecy Act ("BSA"), 31 U.S.C. § 5311 et seq., and its implementing
regulations, which Congress enacted to address an increase in criminal money laundering activities
utilizing financial institutions, require domestic banks, insured banks and other financial institutions
to maintain programs designed to detect and report suspicious activity that might be indicative of
money laundering and other financial crimes, and to maintain certain records and file reports related
thereto that are especially useful in criminal, tax or regulatory investigations or proceedings.
Pursuant to Title 31, United States Code" Section 5318(h)(1) and 12 C.F.R.
§ 563.l77(c), Defendant AMERICAN EXPRESS BANK INTERNATIONAL, was required to
establish and maintain an anti-money laundering (AML) compliance program that, at a minimum: .
(a) provided internal p~licies, procedures, and controls designed to guard against money
(b) provided for 'an individual or individuals to coordinate and monitor day-to-day
compliance with the BSA and AML requirements;
(c) provided for an ongoing employee training program; and
(d) provided for independent testing for compliance conduct