Filed March 23, 2015
American Express has a variety of legal obligations that require it to terminate Card acceptance by a merchant that it learns is engaged in various illegal activities, including, for example, criminal statutes and regulations that prohibit it from participating in money laundering or transacting with restricted countries or organizations. See, e.g., Money Laundering Control Act of 1986, 18 U.S.C. § 1956 (2012); see also, e.g., Bank Secrecy Act, 12 U.S.C. § 1829b, 1951 et seq. (2012); Trading with the Enemy Act of 1917, 12 U.S.C. § 95a, 50 U.S.C. App’x § 1-44 (2012); USA PATRIOT Act § 326, 31 U.S.C. § 5318 (2012). It should also be noted that when American Express reports suspicious activities to the government (SAR filings), which, ultimately, may trigger merchant terminations, it is prohibited from alerting the subject merchant.