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 

) 

) 

) 

) 

) 

 ) 

STIPULATED ORDER FOR COMPENSATORY RELIEF

AND MODIFIED ORDER FOR PERMANENT INJUNCTION

Plaintiff, the Federal Trade Commission (“Commission” or “FTC”) and Defendant 

MoneyGram International, Inc. (“MoneyGram”), stipulate to the entry of this Stipulated Order 

for Compensatory Relief and Modified Order for Permanent Injunction (“Order”), resolving the 

FTC’s Unopposed Motion for Entry of Stipulated Order for Compensatory Relief and Modified 

Order for Permanent Injunction (“Unopposed Motion”). 

 THEREFORE, IT IS ORDERED as follows: 

FINDINGS

1. This Court has jurisdiction over this matter. 

2. On October 21, 2009, the Honorable John F. Grady entered the Stipulated Order for 

Permanent Injunction and Final Judgment (Dkt. No. 13, “2009 Stipulated Order”), resolving 

allegations in the Commission’s Complaint (Dkt. No. 1, “Complaint”) charging Defendant with 

engaging in unfair or deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a), the Telemarketing Act, 15 U.S.C. §§ 6101-6108, and the Telemarketing Sales 

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Rule (“TSR”), 16 C.F.R. Part 310, in the course of providing money transfer services to 

consumers in the United States, through its worldwide money transfer network. 

3. The 2009 Stipulated Order enjoined Defendant 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 actions against problematic agents, 

and ensuring its agents are aware of their obligations to detect and prevent fraud and comply 

with MoneyGram’s policies and procedures (Section III); and share consumer complaint 

information with the FTC for inclusion in Consumer Sentinel, a database available to law 

enforcement (Section IV).

4. Although the parties stipulate to the entry of this Order resolving the allegations in the 

FTC’s Unopposed Motion and modifying the 2009 Stipulated Order by requiring Defendant to 

provide more comprehensive relief to protect consumers worldwide, Defendant neither admits 

nor denies any of the allegations set forth in the Unopposed Motion, except as specifically stated 

in this Order. Only for purposes of this action, Defendant admits the facts necessary to establish 

jurisdiction.

5. Defendant waives any claim that it may have under the Equal Access to Justice Act, 28 

U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, and 

agrees to bear its own costs and attorney fees. 

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6. Defendant and the Commission waive all rights to appeal or otherwise challenge or 

contest the validity of this Order. 

DEFINITIONS

For purposes of this Order, the following definitions apply:

A. “Cash-to-Cash Money Transfer” means the transfer of the value of cash from one 

Person in one location to a recipient (payee) in another location that is received in the 

form of cash.

B. “Cash Reload Money Transfer” means the transfer of the value of cash from one 

Person in one location to a recipient (payee) in another location that is received in a form 

that makes it possible for a Person to convert the cash into an electronic form that can be 

used to add funds to a general-use prepaid card or an account with a payment 

intermediary.

C. “Consumer” means any Person, worldwide, unless otherwise stated, who initiates or 

sends a Money Transfer.

D. “Consumer Fraud” means any fraud or deception involving Fraud-Induced-MoneyTransfers.

E. “Defendant” means MoneyGram International, Inc., its subsidiaries and affiliates, and its

successors and assigns.

F. “Elevated Fraud Countries” means any country in which the principal amount of 

Money Transfers that are the subject of fraud complaints, received by Defendant from 

any source, represents one (1) percent or more of the principal amount of fraud 

complaints worldwide received by Defendant, for Money Transfers either sent or 

received in that country, determined on a quarterly basis, provided that once a country is 

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determined to be one of the Elevated Fraud Countries, it shall continue to be treated as 

such for purposes of this Order.

G. “Elevated Fraud Risk Agent Location” means any MoneyGram Agent location that 

has processed payouts of Money Transfers associated with:

1. Five (5) or more fraud complaints for such agent location, received by Defendant 

from any source, during the previous sixty (60) day period, based on a review of 

complaints on a monthly basis; and fraud complaints, received by Defendant from 

any source, totaling five (5) percent or more of the total payouts for such agent 

location in numbers or dollars in a sixty (60) day period, calculated on a monthly 

basis; or

2. Fifteen (15) or more fraud complaints for such agent location, received by 

Defendant from any source, during the previous sixty (60) day period, based on a 

review of complaints on a monthly basis.

H. “Fraud-Induced Money Transfer” includes any Money Transfer that was induced by, 

initiated, or sent as a result of, unfair or deceptive acts or practices and/or deceptive or 

abusive Telemarketing acts or practices. 

I. “Front Line Employee” means the employee or associate of the MoneyGram Agent

responsible for handling a transaction at the point of sale for a Consumer or a recipient

(payee) of a Money Transfer, including by initiating, sending, or paying out the Money 

Transfer. 

J. “MoneyGram Agent” means any network agent, chain agent, master agent, seller, 

correspondent, authorized delegate, standard agent, independent agent, retail agent, super 

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agent, hybrid agent, subagent, sub-representative, or any location, worldwide, authorized 

by Defendant to offer or provide any of its Money Transfer products or services.

K. “Money Transfer” means the sending of money (in cash or any other form, unless 

otherwise stated) between a Consumer in one location to a recipient (payee) in another 

location using Defendant’s money transfer service, and shall include transfers initiated or 

sent in person, online, over the telephone, using a mobile app, at a kiosk, or through 

whatever platform or means made available, and money transfers received at a kiosk or 

ATM machine. The term “Money Transfer” does not include Defendant’s payment 

services available to Persons to pay bills or make payments, such as Defendant’s urgent 

or utility bill payment services, and Defendant’s pre-paid services for items such as prepaid cards or cellular phones. 

L. “Person” includes a natural person, an organization or other legal entity, including a 

corporation, partnership, sole proprietorship, limited liability company, association, 

cooperative, or any other group or combination acting as an entity. 

M. “Seller” means any Person who, in connection with a Telemarketing transaction, 

provides, offers to provide, or arranges for others to provide goods or services in 

exchange for consideration. 

N. “Telemarketer” means any Person who, in connection with Telemarketing, initiates or 

receives telephone calls to or from a customer. 

O. “Telemarketing” means any plan, program, or campaign which is conducted to induce 

the purchase of goods or services by use of one or more telephones, and which involves a 

telephone call, whether or not covered by the TSR. 

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P. “Unusual or Suspicious Money Transfer Activity” means Money Transfer activity that 

cannot reasonably be explained or justified, including, but not limited to, the following:

1. Data integrity issues, including, but not limited to, invalid, illegible, incomplete, 

missing, or conflicting biographical data for Consumers or recipients of Money 

Transfers; 

2. Significant changes in the transaction patterns experienced at the agent location; 

3. Significant differences in the transaction patterns experienced at the agent 

location relative to the patterns experienced at other agent locations in the same 

country;

4. Activity that is indicative of elder financial exploitation;

5. Irregular concentrations of send and/or pay activity between the agent and one or 

more other MoneyGram Agent locations; 

6. Irregular concentrations of send and/or pay activity between the agent and one or 

more geographical areas that have been identified as high risk for fraud; 

7. Unusual transaction patterns by senders or recipients, including, but not limited 

to, the same individual sending or receiving consecutive Money Transfers from 

the same or different agent locations; 

8. Flipping patterns (shortly after receiving funds, a large portion of the money is 

sent to another recipient);

9. Suspicious structuring or splitting of Money Transfers to avoid recordkeeping,

identification requirements, or reporting required by law;

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10. Suspicious surfing patterns (look-ups of Money Transfers in MoneyGram’s 

system by Front Line Employees that cannot reasonably be explained or 

justified); or

11. Transactions that have characteristics related, or similar, to the transaction(s) that 

was (were) reported as fraud.

I.

PROHIBITED BUSINESS ACTIVITIES

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, employees, 

and all other Persons in active concert or participation with any of them, who receive actual 

notice of this Order, whether acting directly or indirectly, in connection with promoting, offering 

for sale, or providing Money Transfer services, are permanently restrained and enjoined from:

A. Transmitting a Money Transfer that Defendant knows or should know is a Fraud-Induced 

Money Transfer, or paying out a Money Transfer to any Person that Defendant knows or 

should know is using its system to obtain funds from a Consumer, directly or indirectly, 

as a result of fraud;

B. Providing substantial assistance or support to any Seller or Telemarketer that Defendant

knows or should know is accepting from a U.S. Consumer, directly or indirectly, a 

Money Transfer as payment for goods or services offered or sold through Telemarketing; 

C. Failing to do any of the following in connection with Money Transfers initiated by 

Consumers: 

1. Interdict recipients that have been the subject of any complaints about FraudInduced Money Transfers based on information provided to, or that becomes 

known by, Defendant; 

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2. Identify, prevent, and stop Cash-to-Cash Money Transfers and Cash Reload 

Money Transfers initiated or received in the U.S. that Defendant knows or should 

know are being used to pay Sellers or Telemarketers, including, but not limited to, 

by:

a. Asking all U.S. Consumers whether the Money Transfer is a payment for 

goods or services offered or sold through Telemarketing;

b. Declining to process Money Transfers from U.S. Consumers where the 

Money Transfer is a payment for goods or services offered or sold through 

Telemarketing; and

c. Interdicting known Sellers and Telemarketers accepting Money Transfers 

as payments for goods or services offered through Telemarketing; 

3. Provide a clear, concise, conspicuous, and uncontradicted Consumer Fraud 

warning on the front page of all Money Transfer forms, paper or electronic, 

utilized by Consumers in Elevated Fraud Countries to initiate Money Transfers 

using Defendant’s system that includes, at a minimum:

a. A list of the most common types of scams that utilize Defendant’s Money 

Transfer system;

b. A warning that it is illegal for any Seller or Telemarketer to accept 

payments from U.S. Consumers through Money Transfers for goods or 

services offered or sold through Telemarketing; 

c. A notice to Consumers that the Money Transfer can be paid out to the 

recipient within a short time, and after the money is paid out, Consumers’ 

ability to obtain a refund from Defendant may be limited; and

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d. A toll-free or local number and a website for Defendant, subject to the 

timing requirements set forth in Subsection C.4, that Consumers may call 

or visit to obtain assistance and file a complaint if their Money Transfer

was procured through fraud;

4. Make available in all countries in which Defendant offers Money Transfer

services a website that Consumers may visit to obtain assistance and file a 

complaint if they claim their Money Transfer was procured through fraud, 

provided that websites that are not yet available shall be made available in 

accordance with the following schedule: (i) for countries determined to be 

Elevated Fraud Countries as of the entry of this Order, within six (6) months of 

entry of this Order; and (ii) for all other countries, within two (2) years of entry of 

this Order;

5. Provide Consumers who initiate or send Money Transfers via the Internet, 

telephone, mobile app, kiosk, or any other platform that is not in-person, with 

substantially the same clear, concise, conspicuous, and uncontradicted fraud 

warning required by Subsection C.3, provided that the warning may be 

abbreviated to accommodate the specific characteristics of the media or platform;

6. Review and update the Consumer warning, at a minimum annually, to ensure its 

effectiveness in preventing Fraud-Induced Money Transfers; and

7. Submit modifications to the warning, if any, to the Commission for review no less 

than ten (10) business days before any modified warning is disseminated to 

MoneyGram Agents; provided that nothing herein shall prohibit Defendant from 

changing the nature or form of its service, send forms, or media or platform for 

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offering Money Transfer services or from seeking to replace its send forms with 

an electronic form or entry system of some type in the future. In the event such 

changes are made, Defendant shall provide a fraud warning substantially similar 

to that outlined in Subsection C.3 in a form appropriate to the media or platform;

D. Failing to reimburse the principal amount of a Consumer’s Money Transfer and any 

associated Money Transfer fees whenever a Consumer or his or her authorized 

representative reasonably claims that the transfer was fraudulently induced and: 

1. The Consumer or his or her authorized representative asks Defendant, the sending 

agent, or Front Line Employees to reverse the transfer before the transferred funds 

have been picked up; or 

2. Defendant, after reviewing information and data relating to the Money Transfer, 

determines that Defendant, its agents, or the Front Line Employees failed to 

comply with any of Defendant’s policies and procedures relating to detecting and 

preventing Fraud-Induced Money Transfers when sending or paying out the 

Money Transfer by failing to: provide the required Consumer Fraud warnings;

comply with Defendant’s interdiction or callback programs; verify the recipient’s 

identification; or accurately record the recipient’s identification(s) and other 

required biographical data;

E. Failing to promptly provide information to a Consumer, or his or her authorized

representative, who reports being a victim of fraud to Defendant, about the name of the 

recipient of the Consumer’s Money Transfer and the location where it was paid out, when 

such information is reasonably requested; and

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F. Failing to establish and implement, and thereafter maintain, a comprehensive anti-fraud 

program that is designed to protect Consumers by detecting and preventing FraudInduced Money Transfers worldwide, and to avoid installing or doing business with 

agents who appear to be involved or complicit in processing Fraud-Induced Money 

Transfers or who fail to comply with Defendant’s policies and procedures to detect and 

prevent fraud (hereinafter referred to as “Defendant’s Anti-Fraud Program” or 

“Program”). To satisfy this requirement, Defendant must, at a minimum: 

1. Fully document in writing the content and implementation of the Program 

and provide that documentation to the FTC;

2. Implement the Program within four (4) months of the entry of this Order;

3. Design and implement administrative, technical, and physical safeguards 

to detect and prevent Fraud-Induced Money Transfers, accounting for the 

volume and complexity of Defendant’s Money Transfer system. Such 

safeguards shall include at a minimum: 

a. Performance of due diligence on all prospective MoneyGram 

Agents and existing MoneyGram Agents whose contracts are up 

for renewal, which at a minimum meets the requirements in 

Section II of this Order;

b. Designation of a qualified employee or employees to coordinate 

and be accountable for Defendant’s Anti-Fraud Program;

c. Education and training on Consumer Fraud for MoneyGram 

Agents and Front Line Employees, which at minimum address the 

topics listed in Section III.A of this Order; 

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d. Monitoring of MoneyGram Agent and Front Line Employee

activity related to the prevention of Fraud-Induced Money 

Transfers, including, but not limited to, the measures in Section 

III.B of this Order; 

e. Prompt disciplinary action against MoneyGram Agent locations

and Front Line Employees where necessary to prevent FraudInduced Money Transfers, which at minimum meets the 

requirements in Section III.C of this Order; 

f. Systematic controls to detect and prevent Fraud-Induced Money 

Transfers, including, but not limited to:

i. To the extent permitted by law, requiring all Persons to 

provide a government-issued identification document (ID) 

in order to receive a Money Transfer through a 

MoneyGram Agent;

ii. Establishing certain dollar thresholds for Money Transfers 

to Elevated Fraud Countries and holding Money Transfers 

exceeding such dollar thresholds to Elevated Fraud 

Countries until Defendant has confirmed with the sender

that they are not Fraud-Induced Money Transfers or has 

refunded the money to the sender; and

iii. Ensuring that MoneyGram Agent locations are recording

all required information about recipients required by 

Defendant’s policies or procedures or by law, including, 

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but not limited to, their names, addresses, telephone 

numbers, and identifications, before paying out Money 

Transfers; and

g. Periodic evaluation and adjustment of Defendant’s Anti-Fraud 

Program in light of:

i. The results of the monitoring required by Subsection F.3.d

of this Section and Section III of this Order;

ii. Any material changes to Defendant’s operations or 

business arrangements; or

iii. Any other circumstances that Defendant knows or should 

know may have a material impact on the effectiveness of 

Defendant’s Anti-Fraud Program, provided that Defendant 

shall notify the FTC in writing of the adjustments to 

Defendant’s Anti-Fraud Program, and reasons for such 

adjustments, no more than thirty (30) days after any 

material modification to Defendant’s Anti-Fraud Program 

has been implemented.

II.

DUE DILIGENCE ON PROSPECTIVE AND EXISTING 

MONEYGRAM AGENTS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, employees,

and all other Persons in active concert or participation with any of them, who receive actual 

notice of this Order, whether acting directly or indirectly, in connection with promoting, offering 

for sale, or providing Money Transfer services, are hereby restrained and enjoined from:

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A. Failing to conduct thorough due diligence on all Persons applying to become, or 

renewing their contracts as, MoneyGram Agents, including any sub-representative or 

subagent, to avoid installing MoneyGram Agents worldwide who may become Elevated 

Fraud Risk Agent Locations, including, but not limited to, by:

1. Verifying the Person’s government-issued identification;

2. Conducting necessary background checks (criminal, employment, or otherwise)

where permissible under local law;

3. Determining whether information or statements made during the agent application 

process are false or inconsistent with the results of Defendant’s background 

checks or other due diligence;

4. Taking all steps necessary to ascertain, consistent with industry standards and

guidance, whether the prospective agent formerly owned, operated, had been a 

Front Line Employee of, or had a familial, beneficial, or straw relationship with 

any location of any money services business that was suspended or terminated for 

fraud-related reasons, as permitted by applicable laws and regulations (including 

foreign laws and regulations) and with the required cooperation from other 

Money Transfer companies;

5. Ascertaining whether the prospective agent had previously been interdicted by 

Defendant for suspicious activities or had been reported to Defendant as a 

recipient of Fraud-Induced Money Transfers;

6. Conducting an individualized assessment of the particular risk factors involved 

with each MoneyGram Agent application and conducting necessary investigative 

steps consistent with those risks; and

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7. Maintaining information about Defendant’s due diligence, including, but not 

limited to, information about the identities of the agent owners, their governmentissued identifications, and the background check(s) conducted;

B. Failing to reject applications where Defendant becomes aware or should have become 

aware based upon its due diligence that the applicant, or any of the applicant’s subrepresentatives or subagents, presents a material risk of becoming an Elevated Fraud Risk

Agent Location;

C. Failing to ensure that the written agreements entered into with all new MoneyGram 

Agents require them to comply with Section I.C.2 of this Order; 

D. Failing to ensure that all new MoneyGram Agents have effective policies and procedures 

in place at each of the agent’s locations to detect and prevent Fraud-Induced Money 

Transfers and other acts or practices that violate Section I of this Order; 

E. Failing to confirm that MoneyGram Agents whose contracts are up for renewal are 

complying with the terms of their agreements with Defendant, including, but not limited 

to, by having effective policies and procedures in place to detect and prevent FraudInduced Money Transfers; and

F. Failing to require all new MoneyGram Agents, and existing MoneyGram Agents, to: (i) 

disclose and update the identities of any sub-representative or subagent; and (ii) direct 

their subagents or sub-representatives to maintain records on the identities of their Front 

Line Employees.

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III.

MONITORING COMPLIANCE OF MONEYGRAM AGENTS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, employees,

and all other Persons in active concert or participation with any of them, who receive actual 

notice of this Order, whether acting directly or indirectly, in connection with promoting, offering 

for sale, or providing Money Transfer services, are hereby restrained and enjoined from:

A. Failing to provide ongoing education and training on Consumer Fraud for all 

MoneyGram Agents, Front Line Employees, and other appropriate MoneyGram

personnel, including, but not limited to, education and training on detecting, 

investigating, preventing, reporting, and otherwise handling suspicious transactions and 

Fraud-Induced Money Transfers, and ensuring that all MoneyGram Agents and Front 

Line Employees are notified of their obligations to comply with Defendant’s policies and 

procedures and to implement and maintain policies and procedures to detect and prevent 

Fraud-Induced Money Transfers or other acts or practices that violate Section I of this 

Order;

B. Failing to monitor and investigate MoneyGram Agent location activity to detect and 

prevent Fraud-Induced Money Transfers, including, but not limited to:

1. Developing, implementing, adequately staffing, and continuously operating and 

maintaining a system to receive and retain all complaints and data received from 

any source, anywhere in the world, involving alleged Fraud-Induced Money 

Transfers, and taking steps necessary to obtain, record, retain, and make easily 

accessible to Defendant and, upon request, the FTC, all relevant information 

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regarding all complaints related to alleged Fraud-Induced Money Transfers, 

including, but not limited to:

a. The Consumer’s name, address, and telephone number;

b. The substance of the complaint, including the fraud type and fraud 

method, and the name of any Person referenced; 

c. The reference number for each Money Transfer related to the complaint; 

d. The name, agent identification number, telephone number, and address of 

the sending agent(s);

e. The date of each Money Transfer;

f. The amount of each Money Transfer;

g. The Money Transfer fee for each Money Transfer;

h. The date each Money Transfer is received;

i. The name, agent identification number, telephone number, and address of 

the receiving agent(s);

j. The name, address, and telephone number of the recipient, as provided by 

the recipient, of each Money Transfer;

k. The identification, if any, presented by the recipient, and recorded, for 

each Money Transfer;

l. All transactions conducted by the Consumer bearing any relationship to 

the complaint;

m. To the extent there is any investigation concerning, and/or resolution of, 

the complaint:

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i. The nature and result of any investigation conducted concerning 

the complaint;

ii. Any response to the complaint and the date of such response to the 

complaint;

iii. The final resolution of the complaint, the date of such resolution, 

and an explanation for the resolution; and

iv. If the resolution does not include the issuance of a refund, the 

reason for the denial of a refund;

2. Taking steps to identify MoneyGram Agents and Front Line Employees involved 

or complicit in fraud, including, at a minimum, by conducting the reviews and 

analyses set forth in Subsections B.4 and 5 of this Section;

3. Routinely reviewing and analyzing data regarding the activities of MoneyGram 

Agent locations in order to identify the following:

a. Agent locations that have processed transactions associated with two (2) 

or more complaints about alleged Fraud-Induced Money Transfers, 

received by Defendant from any source, during a thirty (30) day period; 

and

b. Elevated Fraud Risk Agent Locations, as defined in Definition G;

4. For agent locations identified pursuant to Subsection B.3.a of this Section,

investigating the agent location by reviewing transaction data and conducting 

analyses to determine if the agent location displayed, at a minimum, the Unusual 

or Suspicious Money Transfer Activity as set forth in Definition P.1-2, 4-9, and 

11, and if Defendant’s findings indicate that the agent location has engaged in any 

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of those activities, fully investigating the agent location as required by Subsection 

B.5 of this Section; and

5. For Elevated Fraud Risk Agent Locations identified pursuant to Subsection B.3.b 

of this Section, fully investigating the agent location by reviewing transaction data 

and conducting analyses to determine if the agent location displayed any Unusual 

or Suspicious Money Transfer Activity as defined in Definition P;

C. Failing to take at least the following actions to prevent further Fraud-Induced Money 

Transfers: 

1. Suspending MoneyGram Agent locations, as follows, pending further 

investigation to determine whether the MoneyGram Agent locations can continue 

operating consistent with this Order’s requirements:

a. For agent locations identified pursuant to Subsection B.3.a of this Section, 

if the investigation of the agent location required by Subsection B.4 of this 

Section is not completed within fourteen (14) days after the agent location

is identified, suspending the MoneyGram Agent location’s ability to 

conduct further Money Transfers until the investigation is completed; and

b. For Elevated Fraud Risk Agent Locations identified pursuant to 

Subsection B.3.b of this Section, immediately suspending the MoneyGram 

Agent’s ability to conduct further Money Transfers until the review 

required by Subsection B.5 of this Section is completed, except that, for a 

MoneyGram Agent that is a bank or bank branch and otherwise subject to 

this immediate suspension requirement by virtue of fraud complaints 

about Money Transfers that are transferred directly into its account 

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holders’ bank accounts, Defendant shall comply with Subsection III.C.1.a. 

and also permanently block, or request that the MoneyGram Agent block,

all further Money Transfers to bank accounts for which Defendant has 

received any fraud complaint;

2. Upon completion of the investigation, terminating, suspending, or restricting 

MoneyGram Agent locations as follows:

a. Terminating or suspending the MoneyGram Agent location, or restricting 

the agent location’s ability to send and/or receive certain Money 

Transfers, if the findings indicate that the MoneyGram Agent location is 

not, or has not been, complying with Defendant’s Anti-Fraud Program and 

other policies and procedures relating to detecting and preventing FraudInduced Money Transfers, including, but not limited to, by failing to 

collect and record required and accurate biographical information about, 

and government-issued identifications for, the recipients of Money 

Transfers; and

b. Terminating the MoneyGram Agent location if the findings indicate that

any of the MoneyGram Agent location’s owners, management, or 

supervisors, or any of its current Front Line Employees are, or may be,

complicit in the Fraud-Induced Money Transfers, the agent location has 

failed to comply with Section IV of this Order, or the agent location has 

repeatedly failed to comply with Defendant’s Anti-Fraud and other 

policies and procedures relating to detecting and preventing FraudInduced Money Transfers;

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3. On at least a monthly basis, ensuring that all MoneyGram Agents in Elevated 

Fraud Countries receive notice of the substance of any complaints Defendant 

received involving transactions processed by the agent locations; and

4. Ensuring that all MoneyGram Agents are enforcing effective policies and 

procedures to detect and prevent Fraud-Induced Money Transfers, or other acts or 

practices that violate Section I of this Order; and

D. Failing to establish anti-fraud controls to ensure that, prior to paying out Money 

Transfers, MoneyGram Agent locations are recording all required information about the 

recipients of Money Transfers, including, but not limited to, the recipients’ names, 

addresses, telephone numbers, and identifications, and are verifying the identification 

presented by the recipients or, for Money Transfers that are directed to bank accounts, are 

recording the identities of the account holders.

IV.

REQUIREMENTS FOR ELEVATED FRAUD RISK AGENT LOCATIONS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, employees,

and all other Persons in active concert or participation with any of them, who receive actual 

notice of this Order, whether acting directly or indirectly, in connection with promoting, offering 

for sale, or providing Money Transfer services, shall require and ensure that all Elevated Fraud 

Risk Agent Locations that are still operating do the following for one (1) year from the date that

Defendant identifies the agent as an Elevated Fraud Risk Agent Location under the terms of this 

Order:

A. For Money Transfers that are not transferred directly into a recipient’s bank account, 

photocopy or scan the identification documents or biometric information presented by the 

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recipient and retain the photocopies or images, along with the receive forms, for a period

of five (5) years; and

B. Demonstrate during compliance reviews or mystery shops, which Defendant shall 

conduct on at least a quarterly basis, that the agent location is complying with the 

requirements in this Section;

Provided, however, that if Defendant reasonably believes that complying with Subsection 

A of this Section for Money Transfers received by an Elevated Fraud Risk Agent Location in a 

particular foreign jurisdiction would violate that jurisdiction’s laws, Defendant may instead, 

upon notice to Commission staff, block all Money Transfers from the United States to that 

Elevated Fraud Risk Agent Location or, with the agreement of Commission staff, take other 

action at that location to protect Consumers from fraud.

V.

SHARING COMPLAINT INFORMATION

IT IS FURTHER ORDERED that, Defendant, Defendant’s officers, agents, employees,

and all other Persons in active concert or participation with any of them, who receive actual 

notice of this Order, whether acting directly or indirectly, shall, in addition to, or as a 

modification of, any other policy or practice that the Defendant may have, including Defendant’s 

ongoing submission of information to the FTC for inclusion in the Consumer Sentinel Network 

(“Consumer Sentinel”):

A. When Defendant is contacted with a complaint about alleged fraudulent activity 

associated with a Money Transfer, provide notice to the Consumer, or his or her 

authorized representative, that (i) Defendant’s practice is to share information regarding 

the Consumer’s Money Transfer and complaint with law enforcement, including a 

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database used by law enforcement authorities in the United States and other countries; 

and (ii) if the Consumer does not want his or her name, address, telephone number, and 

identification shared with law enforcement, Defendant will honor that request unless 

applicable law permits or requires Defendant to provide that information; and 

B. Regularly, but no less often than every thirty (30) days, submit electronically to the FTC, 

or its designated agent, for inclusion in Consumer Sentinel, all relevant information 

Defendant possesses regarding complaints received from Consumers, their authorized 

representatives, or any other source, anywhere worldwide, about alleged Fraud-Induced 

Money Transfers and regarding the underlying transfer itself, including, but not limited 

to, the information set forth in Section III.B.1.a through III.B.1.l. Provided, however, if 

Defendant receives a request from a Consumer or the Consumer’s authorized 

representative, which is documented by Defendant, stating that the Consumer does not 

want his or her name, address, telephone number, and identification shared with the 

database, or if Defendant received the complaint from a source other than the Consumer

or the Consumer’s authorized representative, Defendant shall submit to the FTC an 

anonymized complaint with the Consumer’s name, address, telephone number, and 

identification redacted. Provided, further, that Defendant shall cooperate with the FTC in 

order to facilitate compliance with this Section. 

VI.

CORPORATE COMPLIANCE MONITOR PURSUANT TO DEFERRED 

PROSECUTION AGREEMENT

Defendant shall comply with the Department of Justice’s (“DOJ”) Deferred Prosecution 

Agreement (“DPA”) Corporate Compliance Monitor requirement pursuant to Paragraphs 10 

through 13 and Attachment D of the DPA filed in United States v. MoneyGram International, 

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Inc., No. 12-CR-00291 (M.D. Pa. Nov. 9, 2012) (Docket No. 3), and the subsequent Amendment 

to and Extension of the DPA, filed on November 8, 2018 (Docket No. 34-1) (“DPA

Amendment”), and shall provide the Commission each of the Corporate Compliance Monitor’s 

reports within fifteen (15) days of receipt.

VII.

MONETARY JUDGMENT FOR COMPENSATORY RELIEF

IT IS FURTHER ORDERED THAT: 

A. Judgment in the amount of One Hundred Twenty-Five Million Dollars ($125,000,000) is 

entered in favor of the Commission against Defendant as equitable monetary relief for 

consumer redress.

B. Defendant shall satisfy the judgment in Subsection A of this Section by complying with 

the payment requirements set forth in Paragraphs 10 and 11 of the DPA Amendment filed 

in United States v. MoneyGram International, Inc., No. 12-CR-00291 (M.D. Pa.). 

C. Defendant relinquishes dominion and all legal and equitable right, title, and interest in all 

assets transferred pursuant to this Order and Paragraphs 10 and 11 of the DPA

Amendment and may not seek the return of any assets; 

D. The facts alleged in the Complaint and Unopposed Motion will be taken as true, without 

further proof, in any subsequent civil litigation by or on behalf of the Commission, 

including in a proceeding to enforce its rights to any payment or monetary judgment 

pursuant to this Order, such as a nondischargeability complaint in any bankruptcy case; 

E. The facts alleged in the Complaint and Unopposed Motion establish all elements 

necessary to sustain an action by the Commission pursuant to Section 523(a)(2)(A) of the 

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Bankruptcy Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel 

effect for such purposes; 

F. Defendant acknowledges that its Employer Identification Number, which Defendant must 

submit to the Commission, may be used for collecting and reporting on any delinquent 

amount arising out of this Order, in accordance with 31 U.S.C. § 7701; 

G. All money paid pursuant to this Order and Paragraphs 10 and 11 of the DPA Amendment

shall be deposited into the DOJ or the Department of the Treasury Assets Forfeiture 

Funds. The funds shall be administered by the FTC and DOJ to compensate the fraud 

victims described in the FTC’s Unopposed Motion and the DOJ’s and Defendant’s Joint 

Motion to Extend and Amend the DPA (Docket No. 34). Defendant has no right to 

challenge any actions taken by DOJ, the FTC, or their representatives, pursuant to this 

Subsection; and

H. No asset transfer required by this Order should be deemed, or deemed in lieu of, a fine, 

penalty, forfeiture, or punitive assessment. Defendant’s satisfaction of the judgment 

through a payment pursuant to the DPA Amendment is not intended to alter the remedial 

nature of the judgment.

VIII.

2009 STIPULATED ORDER VACATED

IT IS FURTHER ORDERED that this Order supersedes the 2009 Stipulated Order 

entered by this Court, which is hereby vacated as moot.

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IX.

ORDER ACKNOWLEDGMENT

IT IS FURTHER ORDERED that Defendant obtain acknowledgments of receipt of this 

Order:

A. Defendant, within seven (7) days of entry of this Order, must submit to the Commission 

an acknowledgment of receipt of this Order sworn under penalty of perjury;

B. For ten (10) years after entry of this Order, Defendant must deliver, or cause to be 

delivered, by electronic or other means a copy of this Order to: (1) all principals, 

officers, directors, and LLC managers and members; (2) all employees, agents, and 

representatives who participate in conduct related to the subject matter of this Order, 

including, but not limited to, MoneyGram Agents and employees who are involved in 

any way with Consumer Fraud complaints or who are involved in the hiring, training, or 

monitoring of MoneyGram Agents; and (3) any business entity resulting from any change 

in structure as set forth in the Section titled Compliance Reporting. Defendant must send 

a copy of this Order to current personnel within fourteen (14) days of entry of this Order. 

For all others, delivery must occur before they assume their responsibilities; and

C. From each individual or entity to which a Defendant delivered a copy of this Order, 

Defendant must obtain, within thirty (30) days, a signed and dated acknowledgment of 

receipt of this Order. Provided that, in the event that Defendant is unable to secure such 

acknowledgements from all current MoneyGram Agents, despite notice of this 

requirement, Defendant shall retain proof of distribution of this Order to all current 

MoneyGram Agents, such as an electronic mail receipt, a certified mail receipt, or an 

affidavit of service.

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X.

COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendant make timely submissions to the 

Commission: 

A. One (1) year after entry of this Order, Defendant must submit a compliance report, sworn 

under the penalty of perjury by a senior corporate manager, or a senior officer responsible 

for Defendant’s Anti-Fraud Program, based on personal knowledge or knowledge gained 

from company officials or subject matter experts with requisite knowledge, that: 

1. Identifies the primary physical, postal, and email address and telephone number, 

as designated points of contact, which representatives of the Commission may use

to communicate with Defendant;

2. Identifies any business entity that Defendant has any ownership interest in or 

controls directly or indirectly that may affect compliance obligations arising under 

this Order;

3. Describes in detail whether and how Defendant is in compliance with each 

Section of this Order, including, but not limited to, describing the following:

a. The number of MoneyGram Agents, by country, identified by the 

procedures in Section III.B.3 of this Order;

b. The names, addresses, and telephone numbers of all MoneyGram Agent

locations that have been suspended, restricted, or terminated by Defendant

for reasons related to Fraud-Induced Money Transfers, the dates of and the 

specific reasons for the suspensions, restrictions, or terminations, and, for 

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MoneyGram Agents that have been reactivated after suspension, the dates 

of the reactivations; and

c. Evidence showing that Defendant has and is complying with the 

requirements of Sections I through V of this Order;

4. Indicates that Defendant is not aware of any material noncompliance that has not 

been (1) corrected or (2) disclosed to the Commission; and

5. Includes a copy of each Order Acknowledgment obtained pursuant to this Order, 

unless previously submitted to the Commission.

B. Annually, unless otherwise stated in this Subsection, for a period of twelve (12) years 

after Defendant’s submission of the compliance report required by Subsection A of this 

section, Defendant shall submit a compliance report, sworn under penalty of perjury by a 

senior corporate manager, or a senior officer responsible for Defendant’s Anti-Fraud 

Program, based on personal knowledge or knowledge gained from company officials or 

subject matter experts with requisite knowledge, that: 

1. Notifies the Commission of any change in any designated point of contact within 

fourteen (14) days of the change; 

2. Notifies the Commission of any change in the structure of any entity that 

Defendant has any ownership interest in or controls directly or indirectly that may 

affect compliance obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any subsidiary, parent, or affiliate that 

engages in any acts or practices subject to this Order, within fourteen (14) days of 

the change;

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3. Describes in detail whether and how Defendant is in compliance with each 

Section of this Order, including, but not limited to, describing the following:

a. The number of MoneyGram Agents, by country, identified by the 

procedures in Section III.B.3 of this Order;

b. The names, addresses, and telephone numbers of all MoneyGram Agents 

that have been suspended, restricted, or terminated by Defendant for 

reasons related to Fraud-Induced Money Transfers, the dates of and the 

specific reasons for the suspensions, restrictions, or terminations, and, for 

MoneyGram Agents that have been reactivated after suspension, the dates 

of the reactivations; 

c. Evidence showing that Defendant has and is complying with the 

requirements of Sections I through V of this Order; and

4. Indicates that Defendant is not aware of any material noncompliance that has not 

been (1) corrected or (2) disclosed to the Commission.

C. Defendant must submit to the Commission notice of the filing of any bankruptcy petition, 

insolvency proceeding, or similar proceeding by or against Defendant within fourteen 

(14) days of its filing; 

D. Any submission to the Commission required by this Order to be sworn under penalty of 

perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by 

concluding: “I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct. Executed on: _____” and supplying the 

date, signatory’s full name, title (if applicable), and signature; and

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E. Unless otherwise directed by a Commission representative in writing, all submissions to 

the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by 

overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue 

NW, Washington, DC 20580. The subject line must begin: FTC v. MoneyGram, 

X___________.

XI.

RECORDKEEPING

IT IS FURTHER ORDERED that Defendant must create certain records for twelve (12) 

years after entry of this Order, and retain each such record for five (5) years. Specifically, 

Defendant must create and retain the following records:

A. Defendant’s current written programs and policies governing the detection and 

prevention of Consumer Fraud and the installation and oversight of its agents, including, 

but not limited to, its Anti-Fraud Program; 

B. Defendant’s current policies and procedures governing Consumer Fraud education or 

training provided to MoneyGram Agents or other appropriate personnel;

C. All MoneyGram Agent applications, records reflecting due diligence conducted by 

Defendant with respect to such applications, and with respect to agents whose contracts 

come up for renewal, and written agreements entered into with MoneyGram Agents;

D. Records of all complaints and refund requests, whether received directly or indirectly, 

such as through a third party, from any source, anywhere in the world, about potentially 

Fraud-Induced Money Transfers, and any response, including, but not limited to, the 

information listed in Section III.B.1 of this Order;

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E. Records reflecting all steps Defendant has taken to monitor the activity of its agents to 

detect, reduce, and prevent Consumer Fraud, including, but not limited to, records of 

Defendant’s reviews, audits, or investigations of MoneyGram Agents associated with 

Consumer Fraud, communications with such agents regarding Consumer Fraud matters, 

and any remedial action taken against agents due to fraud; 

F. Copies of documents relating to compliance reviews or mystery shops conducted by 

Defendant of Elevated Fraud Risk Agent Locations pursuant to Section IV of this Order; 

and

G. All records necessary to demonstrate full compliance with each provision of this Order, 

including all submissions to the Commission.

XII.

COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant’s compliance 

with this Order and any failure to transfer any assets as required by this Order: 

A. Within fourteen (14) days of receipt of a written request from a representative of the 

Commission, Defendant must: submit additional compliance reports or other requested 

information, which must be sworn under penalty of perjury; appear for depositions; and 

produce documents for inspection and copying. The Commission is also authorized to 

obtain discovery, without further leave of court, using any of the procedures prescribed 

by Federal Rules of Civil Procedure 29, 30 (including telephonic depositions), 31, 33, 34, 

36, 45, and 69;

B. For matters concerning this Order, the Commission is authorized to communicate directly 

with Defendant. Defendant must permit representatives of the Commission to interview 

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32

any employee or other Person affiliated with Defendant who has agreed to such an 

interview. The Person interviewed may have counsel present; and

C. The Commission may use all other lawful means, including posing, through its 

representatives as Consumers, suppliers, or other individuals or entities, to Defendant or 

any individual or entity affiliated with Defendant, without the necessity of identification 

or prior notice. Nothing in this Order limits the Commission’s lawful use of compulsory 

process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1. 

XIII.

RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order. 

SO ORDERED this day of , 2018. 

____________________________________

UNITED STATES DISTRICT JUDGE

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Dated: ~a"~b&r ~ J .l.o \i:: 

KAREN 0. DODGE 

JOANNIE T. WEI 

Attorneys for Plaintiff 

Federal Trade Commission 

230 South Dearborn Street, Suite 3030 

Chicago, lllinois 60604 

(312) 960-5634 (telephone) (312) 960-5600 (facsimile) 

Director and Chief Executive Officer 

COUNSEL FOR DEFENDANT MONEYGRAM INTERNATIONAL, INC. 

°"JA).v,cL z,V\V\lth Dated: ,Jo.,i. ls,., 1.o)f> 

DAVID M. ZINN 

STEVEN M. CADY 

Attorneys for Defendant 

Williams & Connolly LLP 

725 Twelfth Street, N. W. 

Washington, D.C. 20005-5901 

(202) 434-5880 (telephone) (202) 434-5029 (facsimile) 

33