Federal Reserve Board announces enforcement action against American Express Company to address, among other things, the firm’s failure to sufficiently detect and report certain suspicious activity related to money laundering

AML monitoring systems generate thousands of alerts, but the decision to escalate or dismiss each signal is where regulatory obligation crystallizes. Without a structured record showing who reviewed the alert, why they concluded it did or did not meet SAR thresholds, and what evidence supported that call, the firm cannot prove it discharged its duty to detect and report. The enforcement action reflects a breakdown in decision artifacts: alerts existed, but the governance trail from detection to determination to filing did not. Every suspicious-activity conclusion is a decision that demands an owner and a recorded rationale, produced at the moment of judgment, not reconstructed under examination.