$80 Million in Multistate BSA/AML Settlement for Money Transmitter

Forty-eight state financial regulators, in a multistate action, agreed to settle with a money transmitter on its alleged violations of Bank Secrecy Act (BSA) and anti-money laundering (AML) laws.  The settlement agreement and consent order includes an approximately $79 million administrative penalty and just under $1 million in administrative costs, and requires certain corrective actions.  The money transmitter neither admits nor denies the allegations.

The alleged inadequacies in the money transmitter’s BSA/AML program underlying the consent order were found during state examinations, and most recently identified in a multistate examination performed in 2023.  State regulators alleged that the money transmitter’s non-compliance left it open to potentially supporting money laundering and other illegal activities.

In addition to the monetary relief, the money transmitter must, among other things:

• Appoint a Compliance Management Committee to assist with administering the settlement, which the company’s board will oversee;
• Have an Independent Consultant: (i) review its BSA/AML program, providing a copy of its assessment to the states within nine months of this agreement; and (ii) submit progress reports at least quarterly; and 
• Develop Corrective Action Plans within 90 days for any deficiencies found in the independent assessment.

The enforcement action was brought through the Multi-State MSB Examination Taskforce.