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                                December 19, 2023

       Christophe Y. Le Caillec
       Chief Financial Officer
       American Express Company
       200 Vesey Street
       New York, New York 10285

                                                        Re: American Express
Company
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 10,
2023
                                                            Form 10-Q for the
Quarterly Period Ended September 30, 2023
                                                            Filed October 20,
2023
                                                            File No. 001-07657

       Dear Christophe Y. Le Caillec:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Market Risk Management Process
       Interest Rate Risk, page 75

   1.                                                   We note your
disclosures surrounding interest rate risk, which includes a sensitivity
                                                        analysis that a
hypothetical, immediate 100 basis point increase in market interest rates
                                                        has on your net
interest income. We also note that your 2023 quarterly reports do not
                                                        present tabular or
expanded narrative disclosure under Quantitative and Qualitative
                                                        Disclosures about
Market Risk. Please further expand your sensitivity analysis
                                                        disclosures, in future
filings, to present additional quantitative information that expresses
                                                        an impact your net
interest income resulting from additional selected hypothetical changes
                                                        in interest rates
(e.g., -100 basis point decrease, +/- 50 or +/- 200 basis point change, etc.).
                                                        Additionally, revise
future filings with interim period financial statements to include
                                                        expanded tabular and
more fulsome narrative disclosures regarding changes, to the extent
 Christophe Y. Le Caillec
FirstName LastNameChristophe  Y. Le Caillec
American Express  Company
Comapany19,
December   NameAmerican
              2023        Express Company
December
Page 2    19, 2023 Page 2
FirstName LastName
         material.
2.       Your disclosure also states that you analyze a variety of interest
rate scenarios to
         understand the potential impacts from interest rate changes on the
economic value of
         equity. Please revise your disclosures, in future filings, to provide
a more comprehensive
         discussion of how you use the economic value of equity to manage your
interest rate risk.
         Ensure that your revised disclosures include a discussion of the
model, key
         assumptions and a discussion of any changes in these key assumptions
from period to
         period along with the factors driving any changes. Refer to Item
305(a)(1)(ii)(B) of
         Regulation S-K.
Form 10-Q for the Quarterly Period Ended September 30, 2023

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Table 5: Selected Card-Related Statistical Information, page 7

3.       We note your disclosure of discount revenue as a percentage of billed
business. Please
         revise your disclosures, in future filings, to clarify whether the
discount revenues as a
         percentage of Billed business are similar or different for each of the
identified segments
         billed business and address the reasons for any differences. To the
extent applicable,
         disclose the percentage for each segment and explain reasons for
changes to the
         percentage between any periods being presented.
Business Segment Results of Operations
U.S. Consumer Services
Total Revenues Net of Interest Expenses, page 10

4.       We note your disclosure that effective as of the second quarter of
2023, your U.S. travel
         and lifestyle services (TLS) results are now reported within both the
USCS and
         Commercial Services (CS) segments. Please revise, in future filings,
to quantity and
         disclose the impact on service fees and other revenue, as a result of
the change in the
         allocation of travel and lifestyle revenues to both the U.S. Consumer
and Commercial
         Services segments.
Expenses, page 11

5.       Please revise your disclosure, in future filings, to provide more
quantification of the
         individual components and changes in your expenses relating to the
individual allocated
         service costs, Card Member rewards expense and Card Member services
expense, as well
         as salaries and employee benefits expenses for the periods presented.
Your discussion
         should explain the nature of the expense and explain the extent to
which such changes
         relate to volume and pricing and as it relates to your allocations,
discuss whether there
         have been any changes to any of the specific allocations during the
periods presented.
         Include similar revisions to your discussion of the operating results
for the Commercial
         Services, International Card Service and Global Merchant and Network
Services segments
 Christophe Y. Le Caillec
American Express Company
December 19, 2023
Page 3
         as well.
Consolidated Capital Resources and Liquidity
Table 18: Summary of Customer Deposits and Consolidated Debt, page 23

6.       Please revise, in future filings, to provide a discussion addressing
the average interest rates
         paid on each of the different types of deposits held as well as
addressing the reasons for
         the changes and the resulting impact on both interest expense and the
liquidity needs of
         the company for each of the periods presented. Similar disclosures
should be presented
         within the discussion of operating results for each of the identified
segments.
7.       Please also revise, in future filings, to provide information which
addresses the duration
         characteristics of the deposits and how these characteristics are
considered within your
         processes for managing liquidity and interest rate risk.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Marc Thomas at 202-551-3452 or Robert Klein at
202-551-3847 with any
questions.



FirstName LastNameChristophe Y. Le Caillec                      Sincerely,
Comapany NameAmerican Express Company
                                                                Division of
Corporation Finance
December 19, 2023 Page 3                                        Office of
Finance
FirstName LastName