Global Financial Crimes Surveillance Unit (GFCSU) and the U.S. Investigations Unit (USIU) are part of the broader Global Risk & Compliance organization, operating within Global Financial Crimes Compliance (GFCC). Together, they provide end-to-end oversight and support of global financial crimes investigations. In partnership with GFCC, GFCSU and USIU develop and implement transaction monitoring rules, reports, and other tools to detect potential criminal activity. They investigate suspicious financial behavior and, when necessary, file Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN) or refer cases to internal compliance partners for global reporting. These teams also manage risk related to politically exposed persons (PEPs) through sanctions screening and enhanced due diligence processes, as well as improper payments that may signal bribery, corruption, or other illicit conduct. GFCSU and USIU play a vital role in ensuring compliance with key regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and the Foreign Corrupt Practices Act. They also support law enforcement by providing critical information to combat money laundering, terrorist financing, credit card fraud, identity theft, and other financial crimes.
Customers who present higher money laundering or terrorist financing risks are subject to periodic enhanced due diligence reviews. The USIU’s High-Risk Enhanced Due Diligence (HR EDD) Team is responsible for conducting annual reviews of high-risk customers who hold U.S. issued products with American Express.