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Summary of Deferred Prosecution Agreement and Civil Enforcement Actions Against American Express Bank International

November 13, 2007
SRZ Client Memorandum


On Aug. 6, 2007, the Department of Justice ("DOJ"), the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of Treasury, and the Board of Governors of the Federal Reserve System ("Federal Reserve") simultaneously entered into separate agreements with American Express Bank International ("AEBI " or the "Bank"), an Edge Act corporation organized under section 25A of the Federal Reserve Act, resolving allegations that AEBI failed to maintain an effective antimony laundering ("AML") program. Miami-based AEBI offers traditional private banking services to a target customer base of high net-worth individuals and businesses in South America.

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