1 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION 

 

 ) 

FEDERAL TRADE COMMISSION, 

 

 Plaintiff, 

 

 v. 

 

MONEYGRAM INTERNATIONAL, INC., 

 

 Defendant. 

) 

) 

) 

) Civil Action No. 09-cv-6576 

) 

) 

) 

) 

) 

 ) 

 

FTC’S UNOPPOSED MOTION FOR ENTRY OF STIPULATED ORDER 

FOR COMPENSATORY RELIEF AND MODIFIED ORDER 

FOR PERMANENT INJUNCTION

 

 Plaintiff, the Federal Trade Commission (“FTC”), moves this Court pursuant to Local 

Rule 37.1, Part XII of the Stipulated Order for Permanent Injunction and Final Judgment entered 

by the Court in this matter on October 21, 2009 (“2009 Order” or “Order”), and the Court’s 

inherent authority, to enter the attached Stipulated Order for Compensatory Relief and Modified 

Order for Permanent Injunction. Defendant, MoneyGram International, Inc. (“MoneyGram”), 

has agreed to the entry of the Stipulated Order for Compensatory Relief and Modified Order for 

Permanent Injunction, and has represented to the FTC that it does not oppose this motion. In 

support of the motion, the FTC states the following:1

I. BACKGROUND

MoneyGram offers money transfer services to consumers worldwide through a network 

of approximately 350,000 agent locations in more than 200 countries and territories. Consumers 

 

1

 Because the FTC and MoneyGram have reached a resolution of the allegations in 

this motion, the FTC is not filing any affidavit or evidence in support of this motion. 

MoneyGram neither admits nor denies any of the FTC’s allegations set forth in this motion. 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 1 of 16 PageID #:100
2

wishing to send funds using MoneyGram’s money transfer system may initiate a transaction in 

person, online, through a mobile device, or at a self-service kiosk located at a MoneyGram agent 

location. For many years, money transfers have been a preferred method of payment for 

fraudsters because the money sent through MoneyGram’s system can be picked up quickly at 

many agent locations around the world, and consumers typically are unable to get their money 

back once the funds have been paid out. In addition, for many years, the perpetrators often have 

been afforded anonymity when receiving money though MoneyGram, including, in some 

instances, by having the ability to pick up transfers without presenting identifications (“IDs”) or 

by using fake names, addresses, and IDs. 

On October 21, 2009, the Honorable John F. Grady entered the 2009 Order (Dkt. No. 13) 

against MoneyGram, which resolved the allegations in the FTC’s Complaint (Dkt. 

No. 1). The Complaint alleged that, between at least 2004 and 2008, MoneyGram had assisted 

fraudulent telemarketers by failing to take timely, appropriate, and effective measures to address 

fraud-induced money transfers in its system. The 2009 Order prohibits MoneyGram from, 

among other things, failing to: establish, implement, and maintain a comprehensive anti-fraud 

program that is reasonably designed to protect U.S. and Canadian consumers (Section I); conduct

thorough due diligence on prospective agents and ensure its written agreements require agents to 

have effective anti-fraud policies and procedures in place (Section II); adequately monitor its 

agents by, among other things, providing appropriate and ongoing training, recording all 

complaints, reviewing transaction activity, investigating agents, taking disciplinary action against 

problematic agents, and ensuring its agents are aware of their obligations to detect and prevent 

fraud and to comply with MoneyGram’s policies and procedures (Section III); and share

consumer complaint information with the FTC for inclusion in the Consumer Sentinel Network,

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 2 of 16 PageID #:101
3

a database of consumer fraud complaints maintained by the FTC and available to law 

enforcement (Section IV).2

As a result of the 2009 Order, MoneyGram has made some enhancements to its agent 

oversight and anti-fraud program, but as this motion demonstrates, it has not been in full 

compliance with the terms of the 2009 Order. By agreeing to a Stipulated Order for 

Compensatory Relief and Modified Order for Permanent Injunction, MoneyGram has committed 

to address deficiencies in its anti-fraud program, as well as to improve and expand its program to 

protect consumers worldwide from consumer fraud involving its money transfer system.

II. MONEYGRAM FAILED TO FULLY COMPLY WITH THE TERMS OF THE

2009 ORDER

For years, MoneyGram failed to take all of the steps necessary—and required by the 

2009 Order—to detect and prevent consumer fraud over its money transfer system.

3

 As a result,

MoneyGram’s system continued to be used by fraudsters around the world to obtain money from 

their victims. In some cases, MoneyGram failed to adopt and implement anti-fraud policies and 

procedures consistent with the Order, while in other cases, it failed to properly train its agents, to 

promptly investigate agents that were the subject of fraud complaints, to take the required 

disciplinary actions against all of the problematic agents, and to conduct the required background 

checks to avoid installing agents that might become involved or complicit in frauds. It also 

 2 In November 2012, MoneyGram also entered into a five-year Deferred 

Prosecution Agreement (“DPA”) with the Department of Justice, in which MoneyGram admitted 

that it had criminally aided and abetted wire fraud and failed to maintain an effective AntiMoney Laundering (“AML”) program relating to consumer fraud from 2004 through 2009. As 

part of the DPA, MoneyGram also agreed to implement enhanced compliance obligations with 

respect to its anti-fraud and AML programs. The five-year term of the DPA was scheduled to 

expire in November 2017, but it has since been extended multiple times. United States v. 

MoneyGram Int’l Inc., No. 12-CR-00291 (M.D. Pa. Nov. 9, 2012).

3 MoneyGram’s anti-fraud program is designed, implemented, and administered 

primarily within the United States.

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 3 of 16 PageID #:102
4

failed to record, as well as to share with Consumer Sentinel, all consumer complaints it received

about fraud-induced money transfers. Significantly, moreover, although MoneyGram 

implemented a new interdiction system in April 2015 that was supposed to enhance its ability to 

automatically hold and prevent the payout of money transfers that likely were fraud-induced, this 

interdiction system failed to function properly from approximately April 2015 through October 

2016, thereby failing to prevent millions of dollars in fraud-induced money transfers.

Each of these violations of the 2009 Order is detailed below. Together, the violations 

caused significant consumer losses. 

A. MoneyGram Failed to Promptly Investigate and then Discipline Agent 

Locations with High Levels of Consumer Fraud

In numerous instances, MoneyGram failed to promptly investigate and take the required 

disciplinary actions against some of its agent locations—especially large chain agents—that

exhibited high levels of consumer fraud.

1. MoneyGram’s Failure to Promptly Investigate Certain Agents

The 2009 Order requires MoneyGram to conduct timely consumer fraud investigations of 

any agent location that meets one of the following thresholds: (1) has received two or more fraud 

complaints in a thirty-day period; (2) has fraud complaints amounting to five percent or more of 

the location’s total received transactions, in numbers or dollars, calculated on a monthly basis; or 

(3) has displayed any unusual or suspicious money transfer activity that cannot reasonably be 

explained or justified. (Section III.B.3-4.) MoneyGram is required to complete an investigation 

within 14 or 30 days, depending upon which threshold triggered the investigation. If the 

investigation is not completed within the required time, then MoneyGram must suspend the 

agent location until the investigation is completed. 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 4 of 16 PageID #:103
5

In some instances, MoneyGram failed to conduct the reviews required by the 2009 Order

of agent locations that satisfied these thresholds, or to suspend agents when investigations were 

not completed on time. For example, from approximately March 2015 until at least March 2016, 

MoneyGram did not conduct the required individual reviews of agent locations for certain large

chain agents that met the review thresholds and did not even consider whether any type of 

disciplinary action was necessary at those locations. By failing to conduct individual reviews of 

all locations meeting the Order’s thresholds, MoneyGram violated Section III.B of the Order.

2. MoneyGram’s Failure to Promptly Discipline Certain Agents

In many instances, MoneyGram also failed to promptly discipline certain agent locations

as required by the terms of the 2009 Order. This was especially the case with individual 

locations of large chain agents. 

Under the Order, MoneyGram is required to terminate, suspend, or restrict locations that 

have failed to take appropriate steps to prevent fraud-induced money transfers. It also is required 

to terminate locations that “may be complicit” in fraud-induced money transfers. (Section 

III.B.5.b.) Nevertheless, MoneyGram failed to promptly terminate, suspend, or restrict certain 

agent locations that had high levels of fraud and that had failed to take appropriate steps to 

prevent fraud, including recording required information (such as consumers’ IDs and 

biographical information), training and overseeing employees, monitoring money transfer 

activity, and refusing to pay out suspicious transfers that likely were fraud-induced. In some 

instances, MoneyGram had agent locations that likely were complicit in frauds, but MoneyGram 

did not adequately comply with the Order’s prompt termination requirement. 

Although MoneyGram often took disciplinary actions, including terminations, against 

lower volume, “mom and pop” agents with high fraud levels, it treated large chain agents 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 5 of 16 PageID #:104
6

differently and sometimes failed to take the required disciplinary actions against certain chain 

agent locations that had high levels of fraudulent activity. For example, MoneyGram did not 

begin placing any restrictions on locations of one large chain agent until approximately mid2013, despite the following facts: (1) the chain was the subject of substantially more consumer 

fraud complaints than any other MoneyGram agent worldwide, including other high-volume 

agents; (2) the chain had locations with high levels of fraud and suspicious activities, including 

some locations with fraud rates of more than 25 percent, or even 50 percent, of their money 

transfer activity—when taking into account confirmed and linked fraud; and (3) the chain had 

failed to take appropriate steps to prevent fraud at its locations. Even by mid-2013, MoneyGram 

had only established a pilot program for restricting that chain’s locations. In addition, before

approximately May 2017, MoneyGram did not suspend any locations of that particular chain 

agent, even where that agent’s locations had high levels of fraud and failed to provide the 

required consumer fraud training to their employees, or otherwise demonstrated a pattern of noncompliance with MoneyGram’s policies and procedures.

Information contained in MoneyGram’s own records demonstrates that it has been aware 

for years of high levels of fraud and suspicious activities involving particular agents—including 

large chain agents—yet it sometimes failed to take prompt disciplinary action against those 

agents as required by the 2009 Order. These records demonstrate a range of suspicious 

activities, including, but not limited to, the following: (1) high numbers and patterns of 

complaints; (2) spikes in the number of money transfers received; (3) money transfer amounts 

that exceed the average transfer amount; (4) data integrity issues (issues relating to the recording 

of ID numbers, dates of birth, or other information about recipients); (5) payouts within minutes 

after the money transfers were sent; (6) same ID or addresses used by multiple receivers; 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 6 of 16 PageID #:105
7

(7) flipping (shortly after receiving funds, a large portion of the money is sent to another 

recipient); (8) structuring of transactions; and (9) substantial transfers to high-risk countries 

known for fraud. Under the terms of the 2009 Order, these types of suspicious activities 

triggered a duty by MoneyGram to investigate and, depending on the findings, impose some type 

of disciplinary action.

In fact, MoneyGram established different standards for disciplinary actions involving

large chain agents, even though that practice finds no support in the terms of the 2009 Order. As 

noted, the 2009 Order requires the termination of any agent location that “may be complicit” in 

fraud-induced money transfers. Consistent with that standard, MoneyGram’s “Global AntiFraud Policy and Response Program” generally provides that if MoneyGram finds that the agent 

“may be complicit,” it must be terminated. However, with chain agents, which MoneyGram has 

defined as agents with ten or more locations, MoneyGram’s policy only requires termination “if 

the Chain Agent itself is complicit” in the fraud. (Emphasis added.) That is a different standard 

than the one in Section III of the Order. The Order defines a “MoneyGram Agent” as “any 

person authorized to sell money transfer services marketed by” MoneyGram, and each location 

constitutes a separate agent for purposes of the Order. (Defn. A.) As a result, the Order requires 

that the complicity assessment be made separately with respect to each chain agent location. By 

failing to do that, MoneyGram violated the terms of the Order. In some cases, moreover,

although MoneyGram’s contracts with large chain agents typically provide MoneyGram with the 

authority to suspend money transfer services “until remedial controls have been implemented” at

their locations, they do not provide MoneyGram with the authority to terminate agent locations 

as a remedial measure, even though the Order requires MoneyGram to terminate any location 

that may be complicit in fraud.

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 7 of 16 PageID #:106
8

The written guidelines used by MoneyGram’s Financial Intelligence Unit (“FIU”), which 

is the primary unit responsible for conducting consumer fraud investigations and taking (or

recommending) disciplinary actions against agents in accordance with the 2009 Order, also

demonstrate that MoneyGram established standards for disciplinary actions that did not comply 

with the 2009 Order’s requirements. These guidelines, which were dated April 11, 2013,

required agents to have unreasonably high fraud rates before they would be subject to suspension 

or termination, and also set a higher standard for terminations due to complicity.

For example, these FIU guidelines provided for suspension of an agent location when 

fraud activity represents “greater than 75%” of the location’s transactions, and termination of an 

agent location when fraud activity represents “greater than 90%” of the transactions. (Emphasis 

added.) These guidelines do not comply with the 2009 Order, which requires MoneyGram to 

terminate, suspend, or restrict agents that have not been “taking appropriate steps to prevent” 

fraud-induced money transfers. That standard is satisfied long before the point at which greater 

than 75 percent of an agent’s transactions are determined to be for fraud. The guidelines further

indicate that terminations are appropriate where there is “[a] clear indication of Agent 

complicity.” The standard for terminating agent locations in the 2009 Order, however, requires 

termination when there may be complicity at an agent location, long before fraud activity reaches 

greater than 90 percent or there otherwise is “a clear indication of Agent complicity.” 

B. MoneyGram Failed to Properly Monitor Agents’ Money Transfer Activity 

and Maintain Appropriate Technical Safeguards to Prevent Fraud

The 2009 Order requires MoneyGram to implement a comprehensive anti-fraud program 

that includes appropriate and adequate monitoring of agent activity related to the prevention of

fraud-induced money transfers. (Section I.D.4.) Despite the Order’s requirements, MoneyGram

failed to adequately monitor and prevent the money transfer activity of recipients of fraudCase: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 8 of 16 PageID #:107
9

induced money transfers, including recipients who had been the subject of one or more consumer 

fraud complaints, or who otherwise had engaged in suspicious activity or activity linked to fraudinduced money transfers. In some cases, these recipients were members of fraud rings who

conducted numerous suspicious transfers at one or more agent locations within a particular 

geographic area. Their money transfers also exhibited other suspicious characteristics indicative 

of fraud, such as multiple transfers at the same or different locations on the same day within a 

short period of time, large-dollar amounts or structured money transfers, and suspicious 

biographical information, such as shared or fake addresses or IDs. By adequately monitoring 

this activity, MoneyGram should have been able to prevent these losses.

In addition, although MoneyGram’s anti-fraud program is required to have the 

“administrative, technical, and physical safeguards appropriate to Defendant’s size and 

complexity, and the nature and scope of Defendant’s activities” (Section I.D), MoneyGram 

failed to maintain those technical safeguards for at least an eighteen-month period from April 

2015 through October 2016. During this time, MoneyGram’s interdiction system, which was

supposed to block fraud-induced money transfers, experienced serious technical problems and 

was ineffective at blocking a substantial number of such transfers. As a result, MoneyGram 

allowed individuals that it knew, or should have known, were using its system for fraud to obtain 

the proceeds of their frauds.

In response to the technical problems, MoneyGram failed to add individuals who had 

received, or were linked to, fraud-induced money transfers to its Internal Watch List, which is 

used for blocking fraud-induced money transfers in its system. Consequently, known fraudsters 

were able to continue using the system to obtain money from their victims. By failing to provide

the necessary technical safeguards during this period, MoneyGram violated the Order.

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 9 of 16 PageID #:108
10

C. MoneyGram Failed to Properly Train All Agents

The 2009 Order requires MoneyGram to provide appropriate and adequate ongoing 

education and training for all of its agents on how to detect and prevent consumer fraud (Sections 

I.D.3, III.A), but for years, MoneyGram sometimes failed to provide the required training. 

Although MoneyGram recognizes that its agents and their employees are the “first line of 

defense” in preventing fraud, it provided only limited training to certain agents and also failed to 

ensure that certain agents were properly training their own employees. 

In many cases, MoneyGram adopted the train-the-trainer approach and relied upon its 

agents to provide training to their employees responsible for processing money transfers. 

MoneyGram failed, however, to ensure that the employees of agents responsible for sending and

paying out money transfers were adequately trained about consumer fraud, including with 

respect to detecting and preventing fraud, properly recording consumers’ biographical 

information and IDs, and addressing suspicious activities. For example, an audit of 397 

locations of a large chain agent in 2014 disclosed that 1,863 “primary and secondary” employees 

responsible for processing money transfers had not had either initial or ongoing training, and 68 

percent of secondary employees had not had any training at all. Moreover, even after 

MoneyGram began a new audit procedure in 2015, which involved not only providing advance 

notice of store audits, but also warning about the risk of suspension for non-compliance, the 

audits continued to find that some chain locations had untrained employees and other noncompliance issues. Even so, MoneyGram did not immediately suspend those locations, but 

instead gave them at least thirty days after the audit to train employees and address the noncompliance issues.

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 10 of 16 PageID #:109
11

MoneyGram also failed to ensure that high-fraud agent locations that were required to 

conduct consumer fraud training as a remedial measure had promptly trained their employees to 

prevent future consumer fraud at those locations. In some cases, agents failed for months to 

conduct, or prove that they had conducted, the required consumer fraud training at their

locations, even though the Order requires MoneyGram to take “[p]rompt disciplinary action

against MoneyGram Agents..., including [by] requiring mandatory fraud training.” (Section 

I.D.5.) Despite this requirement, MoneyGram permitted high-fraud agent locations to continue 

to have unfettered access to its system for months before taking further corrective action, such as

by restricting them, to address their failure to train employees. According to MoneyGram’s 

internal guidelines, MoneyGram only recommended restricting a location’s ability to process 

money transfers if it was “[u]nable to complete fraud training within 100 calendar days.” That is 

not “prompt disciplinary action” under the terms of the 2009 Order, as it enabled further fraud to 

be perpetrated through the agent’s untrained employees for another 100 days.

D. MoneyGram Failed to Conduct Thorough Due Diligence of All Agents

Although MoneyGram is required under the 2009 Order to conduct “thorough due 

diligence” on prospective agents in order to avoid installing agents that might become involved 

or complicit in frauds, in some cases, it failed to do so. Under the Order, MoneyGram’s due 

diligence must include, but not be limited to, verifying government-issued IDs, conducting 

reasonable background checks, conducting individualized assessments of applications, and 

conducting reasonable inquiries to ensure that prospective agents were not previously closed 

down by another money services business for fraud-related reasons. (Section II.A.) In some 

instances, MoneyGram’s due diligence failures resulted in the installation of agents that had been 

closed by Western Union due to fraud or had backgrounds indicating that they were at risk for 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 11 of 16 PageID #:110
12

becoming involved or complicit in processing fraud-induced money transfers. MoneyGram also 

sometimes failed to maintain records demonstrating that it had conducted the required due 

diligence.

E. MoneyGram Failed to Record All Consumer Complaints

The Order requires MoneyGram to record all complaints relating to fraud-induced money 

transfers, and to share information about them with the FTC’s Consumer Sentinel Network

unless a consumer requests that the information not be shared with law enforcement.

4 (Sections 

III.B.1 and IV.B.) Despite these requirements, MoneyGram has, in some cases, failed to record,

and ultimately share with the FTC, information that it has received about fraud-induced money 

transfers.

5

 In addition, MoneyGram has failed to provide to Consumer Sentinel all of the 

complaints it received and recorded in its complaint database relating to U.S. and Canadian 

consumers. These failures to record and to share complaint information with Consumer Sentinel 

violate the Order.

III. CONSUMER COMPLAINTS ABOUT FRAUD-INDUCED MONEY TRANSFERS

MoneyGram maintains a database of complaints it receives about fraud-induced money 

transfers. Based on information in that database, between January 1, 2013 and April 30, 2018,

MoneyGram received at least 295,775 complaints about fraud-induced money transfers. These 

complaints relate to a variety of scams, including, but not limited to, online or Internet purchase 

 4 In instances where consumers have requested that their information not be shared 

with law enforcement, MoneyGram has been providing the FTC with their anonymized 

complaint information.

5 This failure affects multiple aspects of MoneyGram’s anti-fraud program, as well 

as compliance with the Order, since the complaint information is supposed to be used for 

purposes of identifying, investigating, and taking disciplinary actions against agents. It also is 

important for MoneyGram to share this information with the FTC, so that it can be made 

available to other law enforcement agencies that have access to Consumer Sentinel and use it for 

law enforcement purposes.

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 12 of 16 PageID #:111
13

scams, person-in-need scams, investment scams, romance scams, and lottery or prize scams.

Approximately 77 percent of the complaints in the database are from U.S. consumers and 

approximately 6 percent of the complaints are from Canadian consumers.

Moreover, a discrete set of agents processed most of the transactions related to the 

consumer fraud complaints. In fact, based on MoneyGram’s complaints, only approximately 

3.71 percent of its agents worldwide (approximately 13,000 locations) have received five or 

more fraud complaints since January 1, 2013, yet those agents account for approximately 84.48 

percent of all complaints to MoneyGram.

The complaints in MoneyGram’s database represent only a small percentage of the actual 

fraud perpetrated through its system because most victimized consumers do not complain 

directly to MoneyGram. In addition, as noted above, MoneyGram has not included information 

in its database about all of the complaints it has received about fraud-induced money transfers. 

Therefore, MoneyGram’s database understates the actual amount of fraud through its money 

transfer system.

Despite MoneyGram’s obligations to implement and maintain adequate and effective 

anti-fraud and AML programs designed to detect and prevent consumer fraud pursuant to the 

2009 Order and the DPA, between 2012 and 2016, consumer fraud complaints to MoneyGram 

more than doubled, from approximately 26,485 complaints in 2012 to approximately 75,628 

complaints in 2016. During the FTC’s investigation of MoneyGram’s compliance with the 2009 

Order, MoneyGram began taking more meaningful disciplinary actions against agents—

especially large chain agents—and complaints went down significantly in 2017. 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 13 of 16 PageID #:112
14

IV. RELIEF REQUESTED

Without admitting or denying the allegations described herein, and in order to resolve 

those allegations, MoneyGram has agreed to the entry of a monetary judgment for compensatory 

relief in the amount of $125 million. Courts possess the inherent authority to enforce compliance 

with their orders. FTC v. Asia Pac. Telecom, Inc., 788 F. Supp. 2d 779, 789 (N.D. Ill. 2011). 

Obedience to judicial orders is a fundamental expectation of our legal system. In particular, 

injunctions issued by a court of competent jurisdiction must be obeyed until withdrawn or 

vacated. W.R. Grace & Co. v. Local Union 759, 461 U.S. 757, 766 (1983); APC Filtration, Inc. 

v. Becker, 2010 U.S. Dist. LEXIS 125871, at *3 (N.D. Ill. Nov. 30, 2010). Courts have “wide

discretion in fashioning an equitable remedy for civil contempt.” McGregor v. Chierico, 206 

F.3d 1378, 1385 n.5 (11th Cir. 2000) (citing United States v. City of Miami, 195 F.3d 1292, 1298 

(11th Cir. 1999)). Where consumers suffer losses as a result of the violation of an FTC 

injunction, compensatory relief is the appropriate remedy. FTC v. Trudeau, 662 F.3d 947, 950 

(7th Cir. 2011); McGregor, 206 F.3d at 1388-89. 

MoneyGram also has agreed to the entry of an order modifying the 2009 Order to include 

a broader range of relief, including a requirement to interdict (or block) the transfers of known 

fraudsters and provide refunds for non-compliance with certain policies or procedures. This 

relief is necessary to address MoneyGram’s non-compliance with the Order, including 

deficiencies in its anti-fraud program. This Court has the power to modify the terms of its 

injunctions in the event that changed circumstances require a modification. See McGregor, 206 

F.3d at 1386, n.9; United States v. Oregon, 769 F.2d 1410, 1416 (9th Cir. 1985). For the reasons 

described above, there has been a change in circumstances, which warrants expanding the 

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 14 of 16 PageID #:113
15

injunctive relief to ensure that MoneyGram is maintaining an adequate and comprehensive antifraud program designed to protect consumers.

V. CONCLUSION

For the foregoing reasons, the FTC respectfully requests that the Court enter the 

Stipulated Order for Compensatory Relief and Modified Order for Permanent Injunction.

MoneyGram has represented to the FTC that it does not oppose this motion.

Dated: November 8, 2018 Respectfully Submitted,

 

/s/ Karen D. Dodge 

KAREN D. DODGE

JOANNIE T. WEI

Attorneys for Plaintiff

Federal Trade Commission

230 South Dearborn Street, Suite 3030

Chicago, Illinois 60604

(312) 960-5634 (telephone)

(312) 960-5600 (facsimile)

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 15 of 16 PageID #:114
CERTIFICATE OF SERVICE

I, Karen D. Dodge, an attorney, hereby certify that, on November 8, 2018, I caused to be 

served a true copy of the foregoing FTC’s Unopposed Motion for Entry of Stipulated Order 

for Compensatory Relief and Modified Order for Permanent Injunction, with written 

consent, by electronic mail on:

DAVID M. ZINN

STEVEN M. CADY

Attorneys for Defendant

Williams & Connolly LLP

725 Twelfth Street, N.W.

Washington, D.C. 20005-5901

dzinn@wc.com

scady@wc.com

/s/ Karen D. Dodge 

KAREN D. DODGE

Attorney for Plaintiff

Federal Trade Commission

230 South Dearborn Street, Suite 3030

Chicago, Illinois 60604

(312) 960-5634 (telephone)

(312) 960-5600 (facsimile)

Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 16 of 16 PageID #:115