American Express Centurion Bank
                            6985 Union Park Center
                             Midvale, Utah 84047


                               January 3, 2000


American Express Centurion Bank
6985 Union Park Center
Midvale, Utah 84047


          Re:  Registration Statement on Form S-3
               Registration No. 333-91473
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Ladies and Gentlemen:

         I have acted as counsel to American Express Centurion Bank ("Centurion
Bank") in connection with the above-referenced Registration Statement on Form
S-3 being filed concurrently herewith with the Securities and Exchange
Commission (the "Registration Statement") under the Securities Act of 1933, as
amended (the "Act"), relating to the proposed issuance and sale of Asset Backed
Certificates (the "Certificates") of the American Express Credit Account Master
Trust to which Centurion Bank and American Express Receivables Financing
Corporation II ("RFC II") will transfer receivables (the "Receivables")
generated from time to time in a portfolio of designated card accounts. The
American Express Credit Account Master Trust was formed pursuant to the Pooling
and Servicing Agreement, dated as of May 16, 1996, among Centurion Bank, RFC II,
American Express Travel Related Services Company, Inc., as Servicer (the
"Servicer"), and The Bank of New York, as trustee (the "Trustee") (the "Pooling
Agreement"). The Certificates will be issued and delivered in accordance with
the terms of a specified Series Supplement to the Pooling Agreement.

         I or members of my staff have examined the Pooling Agreement, form of
Series Supplement and form of Underwriting Agreement included as exhibits to the
Registration Statement. In addition, we have examined and considered executed
originals or counterparts, or certified or other copies, identified to my
satisfaction as being true copies, of such certificates, instruments, documents
and other corporate records of Centurion Bank and matters of fact and law as I
deem necessary for the purposes of the opinion expressed below. Capitalized
terms not otherwise defined herein have the respective meanings assigned to such
terms in the Pooling Agreement.

         In my examination I have assumed the genuineness of all signatures, the
authenticity of all documents submitted to me as originals, the conformity to
original documents of all documents submitted to me as certified or photostatic
copies and the authenticity of the original of such latter documents.

         Based upon the foregoing, and subject to the qualification that I am
admitted to the practice of law in the State of New York and do not purport to
be expert in the laws of any jurisdiction other than the State of New York, I am
of the opinion that, assuming the due execution and delivery of the Pooling
Agreement and applicable Series Supplement thereto





substantially in the form filed as an exhibit to the Registration Statement,
upon the issuance, authentication and delivery of the Certificates in
accordance with the provisions of such Pooling Agreement and such Supplement,
against payment therefor, the Certificates will be legally issued, fully paid
and non-assessable.

         I consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to me under the caption "Legal
Matters" in the Prospectus included in the Registration Statement.


                                             Very truly yours,

                                             /s/ Robert D. Kraus
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                                             Robert D. Kraus
                                             Group Counsel