It's not clear how much scrutiny the company is under for management's role in developing and training employees to sell the product. Subpoenas are issued to compel parties such as company executives and employees, or former employees, to appear for interviews or turn over documents. In July, the OCC assessed a $15 million civil penalty against American Express National Bank. The IRS is also involvedBrooklyn attorneys are coordinating their criminal investigation alongside the IRS's criminal-investigation unit, the people BI spoke with said. Sinking morale among some sales employeesThe investigations are taking a toll on Amex's results-driven culture, current and former sales employees told BI, because compliance staff have gotten more involved in the sales process.

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