Vice President, Third Party Payment Processors & Network Access Financial Crime Program Oversight

Global Financial Crimes Compliance (GFCC), within Global Risk & Compliance (GRC), is responsible for enterprise-wide Anti-Money Laundering (AML), Sanctions, and Anti-Corruption compliance programs. GFCC provides independent second line (2LOD) oversight of financial crime risks and partners closely with business, risk, and control functions across the enterprise.

As payment ecosystems evolve through embedded finance, ATM networks, joint ventures, marketplaces, digital wallets, bill pay providers, acquiring models, program managers, payment facilitators, and other network-based and third-party structures, strong and consistent financial crime governance across third-party models is critical.

Reporting to the Global Head of Sanctions and Cross-Border Risk, the Vice President will build, lead, and operate the global 2LOD financial crimes oversight framework for third-party payment processors and business activities.

This role has global 2LOD portfolio-level accountability for financial crime oversight of all third-party relationships, including but not limited to ATM networks, joint ventures, marketplaces, wallets, bill pay providers, embedded finance partners, acquiring models, program managers, payment facilitators, and other network-based payment structures across U.S. and international legal entities. This will ensure that potential regulatory exposure across AXP’s global network is identified, understood, and addressed in a consistent manner across all markets and lines of business.

This role carries explicit 2LOD authority to help establish enforceable standards, escalate areas for remediation, escalate material risks, drive the 1LOD to adhere to partner consequence management standards, and recommend to 1LOD that contractual compliance expectations are consistently applied globally.  This will require extensive collaboration across markets, lines of business, lines of defense, and the regional heads of GFCC.

This is a hybrid role requiring presence in an American Express office at least three days per week.

Key Responsibilities

Global Oversight, Risk Governance, & New Product Approval

• Design, implement, and operate a comprehensive global 2LOD oversight framework for all third-party partners aligned with enterprise financial crime risk management standards.
• Lead 1LOD in use of the New Product Approval (NPA; inclusive of M&A and Corp. Dev. Initiatives, where applicable) for all new third-party partnerships and payment models, ensuring business partners understand the financial crime risks which have been identified, have been assessed, mitigated, and controls have been formally approved prior to launch.
• Ensure 1LOD monitors all third-party partner activity operate within established financial crime risk appetite; escalate material deviations to 1LOD business partners and GFCC leadership, drive effective challenge and consequence management where necessary, and formally document risk acceptance decisions where required.
• Ensure the First Line of Defense (1LOD) independently risk-ranks all third-party relationships based on inherent and residual risk.
• Partner with the GFCC Risk Assessment team to conduct independent 2LOD financial crime risk assessments for all material third-party relationships and validate the appropriateness of 1LOD risk rankings.
• Ensure, where applicable, 1LOD partner risk ratings are independently validated and used to drive differentiated oversight, including on-going monitoring intensity, periodic and trigger-based review frequency, escalation thresholds, control testing depth, and enhanced monitoring.
• Participate in relevant 1LOD monitoring councils and committees across all business lines to ensure consistent monitoring expectations, rule calibration standards, investigative trend analysis, and escalation protocols.
• Coordinate closely among the three Regional GFCC leaders, Line of Business Compliance Officers (LOBCOs), 1LOD, and relevant business lines to ensure globally consistent oversight while addressing jurisdiction-specific regulatory requirements and market nuances.
• Oversee and, as appropriate, drive across all regions various GFCC project milestones, deliverables, and implementation tasks as they relate to third-party oversight.
• Attend and present material risks, emerging trends, and escalations to senior leadership and formal risk committees and boards across U.S. and international legal entities.
• Ensure enforcement actions and escalation standards are consistently applied across regions and business lines, while maintaining jurisdictional flexibility due to l