1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

 

 ) 

FEDERAL TRADE COMMISSION, ) 

 ) 

 Plaintiff, ) 

 ) Case No. 1:22-cv-3372 

 v. ) 

 ) 

WALMART INC., ) 

 ) 

 Defendant. ) 

 ) 

 

AMENDED COMPLAINT FOR PERMANENT INJUNCTION, MONETARY RELIEF, 

CIVIL PENALTIES, AND OTHER RELIEF 

 Plaintiff, the Federal Trade Commission (“FTC”), for its complaint alleges: 

1. The FTC brings this action under Sections 5(m)(1)(A), 13(b), and 19 of the 

Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(m)(1)(A), 53(b), and 57b, and the 

Telemarketing and Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 

U.S.C. §§ 6101–6108, which authorize the FTC to seek, and the Court to order, permanent 

injunctive relief, monetary relief, civil penalties, and other relief for Defendant’s acts or practices 

in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and in violation of the FTC’s 

Trade Regulation Rule entitled “Telemarketing Sales Rule” (“TSR”), as amended, 16 C.F.R. Part 

310, in connection with Defendant’s failure to take timely, appropriate, and effective measures to 

detect and prevent fraud in the processing of money transfers sent and received by consumers at 

its store locations. 

SUMMARY OF CASE

2. Money transfers are a common vehicle for fraud because money can be sent 

quickly to locations all over the world with limited recourse for consumers. Walmart offers 

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consumers the ability to send and receive money transfers through its stores, and for many years, 

consumers have reported tens of millions of dollars annually in money transfers processed by 

Walmart employees that were induced by fraud. These practices have harmed many consumers, 

including people struggling with debt, those threatened by imposters, and older Americans. 

Walmart is well aware that telemarketing and other mass marketing frauds, such as lottery, prize, 

and sweepstakes scams, advance-fee loan scams, person-in-need, grandparent, and emergency 

scams, and government imposter and utility scams, induce people to use Walmart’s money 

transfer services to send money to domestic and international fraud rings. However, consumers 

generally are not aware of the fraud risks associated with money transfers, and Walmart has 

continued to process fraud-induced transfers at its stores while failing to take sufficient steps to 

warn consumers of the risks and help them make informed choices. 

3. Fraud-induced transfers often exhibit unusual or suspicious characteristics that 

should enable Walmart to detect and prevent consumer losses. For example, these transactions 

frequently involve substantially higher dollar amounts—individually or in the aggregate—than 

typical interpersonal transfers, multiple transfers in relatively short periods of time, back-to-back 

transfers, transfers to locations outside the U.S., often to high-risk countries known for fraud, 

recipients using fake IDs or out-of-state IDs in picking up the transfer, transfers between 

individuals with no apparent relationship, the same person using different names or address 

variations when sending or picking up multiple money transfers, and/or transactions that switch 

between the money transfer systems of MoneyGram International, Inc. (“MoneyGram”), RIA 

Financial Services, a subsidiary of Euronet Worldwide, Inc. (together, “Ria”), and The Western 

Union Company (“Western Union”). Elderly consumers also are frequently the targets of these 

scams, and many such consumers are first-time users of the money transfer systems at Walmart 

locations. 

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4. Walmart has continued processing fraud-induced money transfers at its stores—

funding telemarketing and other scams—without adopting policies and practices that effectively 

detect and prevent these transfers. In some cases, Walmart’s practices have even made it easier 

for fraudsters to collect fraud-induced money transfers at a Walmart store. For example, for 

years, it was Walmart’s policy or practice not to deny payouts to suspected fraudsters at its 

stores, but instead to have its employees complete those transactions. Walmart also has 

maintained, and continues to maintain, a deficient anti-fraud program, including by failing to 

properly train and supervise employees, warn consumers, and monitor and investigate suspicious 

activity. 

5. Walmart’s failure to take timely, appropriate, and effective action to detect and 

prevent fraud-induced money transfers at its stores has caused substantial injury to consumers 

that consumers cannot reasonably avoid themselves and that is not outweighed by countervailing 

benefits to consumers or competition. 

6. Walmart also has provided substantial assistance or support to sellers or 

telemarketers who are violating various provisions of the TSR. First, Walmart for many years 

did nothing whatsoever to attempt to comply with the TSR’s ban on the use of cash-to-cash 

money transfers as payment for goods or services offered or sold through telemarketing or for 

charitable contributions solicited or sought through telemarketing. That ban, which took effect 

in June 2016, imposes obligations on money transfer businesses like Walmart to avoid 

processing violative transfers, but Walmart failed to take appropriate steps to prevent those types 

of transfers at its locations. The TSR prohibits all cash-to-cash money transfers in telemarketing 

transactions, not just those that are fraud-induced. Despite the ban, Walmart for years did not 

take steps to attempt to identify banned transfers, such as by directing its employees to ask 

questions about whether transfers were related to telemarketing and warning consumers that 

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those transfers were illegal. This remained the case even after Walmart received a copy of the 

Commission’s January 2017 order with Western Union, which included similar requirements. 

By continuing to process money transfers without taking any steps to attempt to identify those 

transfers that would be prohibited by the cash-to-cash ban, Walmart has provided substantial 

assistance or support to sellers or telemarketers while consciously avoiding knowing that they 

are violating the TSR’s cash-to-cash ban. 

7. Even today, in some instances, Walmart employees still do not ask questions to 

attempt to determine whether a consumer’s money transfer is a payment for goods or services 

offered or sold through telemarketing or for a charitable contribution solicited or sought through 

telemarketing. In other instances, Walmart also does not provide consumers with a clear, 

concise, and conspicuous warning that it is illegal for any seller or telemarketer to accept a cashto-cash money transfer as payment for goods or services offered or sold through telemarketing or 

payment for a charitable contribution solicited or sought through telemarketing. 

8. In addition to violating the cash-to-cash ban, for years, Walmart has provided 

substantial assistance or support to sellers or telemarketers that it knew or consciously avoided 

knowing have been violating the TSR by (1) making false or misleading statements to induce 

people to pay for goods, services, or charitable contributions, such as through prize and lottery 

scams, government imposter and utility scams, and person-in-need and grandparent scams, or (2) 

requesting or receiving advance fees for a loan or other extension of credit while guaranteeing or 

representing a high likelihood of success in obtaining a loan or extension of credit. Because of 

Walmart’s failures to detect and prevent these telemarketing-related transactions, consumers 

have lost, and continue to lose substantial sums through money transfers effected at Walmart.

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JURISDICTION AND VENUE

9. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

10. Venue is proper in this District under 28 U.S.C. § 1391(b)(2), and (c)(2), and 15 

U.S.C. §§ 53(b) and 6105(b). 

PLAINTIFF

11. The FTC is an independent agency of the United States Government created by 

the FTC Act, which authorizes the FTC to commence this district court civil action by its own 

attorneys. 15 U.S.C. §§ 41–58. The FTC enforces Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. The FTC 

also enforces the Telemarketing Act, 15 U.S.C. §§ 6101–6108. Pursuant to the Telemarketing 

Act, the FTC promulgated and enforces the TSR, 16 C.F.R. Part 310, which prohibits deceptive 

and abusive telemarketing acts or practices. 

DEFENDANT 

12. Defendant Walmart Inc., formerly known as Wal-Mart Stores, Inc. (“Walmart”), 

is a Delaware corporation with its principal place of business at 702 S.W. 8th Street, Bentonville, 

Arkansas 72716. Walmart transacts or has transacted business in this District, as well as 

throughout the United States and in other countries worldwide. 

COMMERCE

13. At all times relevant to this Complaint, Defendant has maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

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DEFENDANT’S BUSINESS PRACTICES 

14. Walmart offers a variety of financial services to its customers at its Customer 

Service Desks, which are located in all of its stores, and in its MoneyCenters, which are 

dedicated spaces for financial services located in less than half of Walmart’s stores. Walmart’s 

advertisements boast that it is “trusted by millions of customers as their one-stop shop for 

financial services.” Walmart’s financial services include, but are not limited to, money transfers, 

credit cards, reloadable debit cards, gift cards, check cashing, bill payment, and money orders. 

These financial services play a role in driving customer traffic to Walmart’s stores, thereby 

generating significant retail sales for Walmart.

15. Consumers can use Walmart’s money transfer services to send and receive money 

from its locations. Walmart relies on other companies’ money transfer systems to provide these 

services. These companies, also referred to as providers, principals, licensed partners, or vendors 

(hereinafter “providers”), include MoneyGram, Ria, and Western Union. Walmart acts as an 

agent of these providers, and Walmart itself has been licensed as a money services business 

(“MSB”) in the United States since December 2001. Walmart offers money transfer services to 

consumers at thousands of locations in the United States and Puerto Rico, as well as in many 

other countries around the world, including, but not limited to, Mexico, Canada, the United 

Kingdom, Argentina, Guatemala, and Costa Rica. 

16. Since at least 2005, Walmart has offered domestic and international money 

transfer services through MoneyGram at Walmart locations within the United States, Puerto 

Rico, and Mexico. In 2018, Walmart began offering its own lower-cost money transfer service, 

called “Walmart2World Money Transfers Powered by MoneyGram,” which allows consumers to 

send up to $2,500 from a Walmart location to be picked up at one of MoneyGram’s agents that 

are located in 200 countries.

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17. In April 2014, in addition to providing traditional money transfer services through 

MoneyGram, Walmart began offering its own white-label money transfer service, referred to as 

“Walmart2Walmart Money Transfers Powered by Ria,” at many of its locations. This service 

originally allowed consumers to send money transfers from one Walmart location to be picked 

up at another Walmart location in the United States and Puerto Rico. In October 2016, Walmart 

expanded Walmart2Walmart services to offer money transfers to and from its stores in Mexico. 

In June 2017, Walmart also began offering Walmart2Walmart services in the United Kingdom 

through its subsidiary Asda Stores Ltd. In November 2019, Walmart announced that it was 

adding Ria as an additional money transfer provider for its Walmart2World international money 

transfers. 

18. Walmart uses its own point-of-sale system to process money transfers that are 

sent and received from its locations through any money transfer company. Walmart also uses 

this system to exchange information with its providers. Walmart designed and controls the 

system in which its employees record information about money transfer senders and receivers, 

and whether and how its point-of-sale system can be used to stop fraud-induced transfers.

19. Since 2007, Walmart has offered domestic and international money transfer 

services to consumers in Canada through Western Union. Walmart also offers Western Union’s 

money transfer services at its locations in other countries, such as Mexico, Great Britain (through 

Asda), Argentina, Guatemala, Costa Rica, Honduras, El Salvador, Nicaragua, Belgium, the 

Philippines, Nigeria, and Qatar. In the spring of 2021, Walmart began offering money transfer 

services through Western Union at Walmart locations in the United States.

20. For over a decade, fraudsters around the world have used money transfers to 

obtain money from their victims, especially U.S. consumers, and Walmart has long been aware 

that its locations have been used to perpetrate these frauds. Walmart has known that these 

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scams—including lottery, prize, and sweepstakes scams, advance-fee loan scams, government 

imposter and utility scams, and person-in-need, grandparent, and emergency scams, among 

others—often have involved telemarketing. Despite its awareness of a substantial amount of 

fraud-induced money transfers involving Walmart, for many years, Walmart has failed to 

effectively detect and prevent consumer fraud involving money transfers at its locations. This 

has been the case despite the fact that, as an agent of both MoneyGram and Western Union, 

Walmart’s contracts with those providers and the stipulated court orders obtained by the FTC 

against MoneyGram and Western Union provided Walmart with notice about its obligations to 

detect and prevent consumer fraud at its locations. FTC v. MoneyGram International, Inc., No. 

09-cv-6576 (N.D. Ill. Oct. 19, 2009); and FTC v. The Western Union Company, No. 17-cv-0110 

(M.D. Pa. Jan. 19, 2017).

21. One of the ways in which Walmart’s anti-fraud practices have been deficient is in 

the training of its frontline employees, as well as its supervisors and managers, referred to 

internally as associates (collectively “employees” or “associates”). In many cases, Walmart has 

failed to properly train and oversee employees responsible for detecting and preventing 

consumer fraud involving money transfers at its locations. These deficiencies have included 

Walmart’s failure to provide employees with adequate initial and ongoing training on detecting 

and preventing consumer fraud, including training about questioning and warning consumers, 

and rejecting and stopping suspected fraud-induced money transfers. Walmart also failed to 

ensure that its employees providing money transfer services are knowledgeable about the 

policies and procedures necessary for detecting and preventing consumer fraud. Until sometime 

in 2019, Walmart failed to provide any instructions to its employees or warnings to consumers 

that specifically addressed the June 2016 amendment to the TSR (“TSR Amendment”), which 

the FTC announced on December 14, 2015. 

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22. The TSR Amendment prohibits the use of “cash-to-cash” money transfers for 

goods or services offered or sold through telemarketing or charitable contributions solicited or 

sought through telemarketing. 

23. Walmart has also failed to adequately monitor money transfer activity and address 

suspicious money transfer activities at its locations, including by employees who have been 

complacent in detecting and preventing consumer frauds or, in some cases, were engaged in 

suspicious activities or even complicit in frauds. In many cases, Walmart has facilitated scams 

by paying out fraud-induced money transfers in violation of its providers’ anti-fraud or AntiMoney Laundering (“AML”) policies and procedures, or by failing to implement and maintain 

its own anti-fraud program designed to detect and prevent consumer fraud at its locations. For 

example, for many years, Walmart’s decision not to train or instruct its employees to deny or 

reject payouts of money transfers that were suspicious and potentially due to fraud allowed 

fraudsters to more easily receive payouts of fraud-induced money transfers at Walmart locations. 

In addition, Walmart has failed to properly train and ensure that its employees are 

knowledgeable about other basic and important procedures, such as verifying and accurately 

recording IDs and other customer information and addressing suspicious activity. Walmart also 

has failed to ensure that its locations are routinely providing required consumer fraud warnings. 

24. Over the years, compliance reviews and audits of Walmart stores by MoneyGram 

and Ria have documented some of the deficiencies in Walmart’s anti-fraud program. For 

example, MoneyGram’s reviews in 2018 and 2019 found that hundreds of Walmart associates 

lacked knowledge about basic and important procedures, such as ID acceptance and 

requirements and how to address suspicious activity. And between January and August 2019, 

Ria found that 39 percent of the Walmart stores it visited were missing fraud awareness materials 

and 24 percent of the stores were missing the send forms, which provide a consumer fraud 

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warning on the front page. Similar problems with untrained associates and fraud awareness 

materials have existed for years and have been reported to Walmart by MoneyGram and Ria. As 

far back as 2014, for example, a MoneyGram audit of 397 Walmart locations revealed that 39 

percent of Walmart locations had untrained primary employees providing money transfer 

services at its Customer Services Desks and MoneyCenters and 60 percent of the locations had 

untrained secondary or backup employees.

Walmart’s Money Transfer Services 

25. Consumers wishing to send or receive funds through a money transfer at a 

Walmart location can visit Walmart’s Customer Service Desks and MoneyCenters. Consumers 

can also initiate money transfers online at Walmart.com or through Walmart’s Mobile Express 

Money Service App and finalize them at a Walmart location. In or around mid-2017, Walmart 

began installing kiosks at some of its Customer Service Desks and MoneyCenters as an option 

for consumers to initiate their money transfers. After using the kiosks to stage their money 

transfers, consumers are required to finalize the transactions at the counter with a Walmart 

associate. 

26. Money transfers sent or received by consumers through Walmart’s providers are 

supposed to be for person-to-person use and not for businesses. Walmart does not limit the 

maximum amount a consumer can send or receive through a Walmart money transfer. Instead, it 

relies on its providers to impose the limits. For years, the maximum amount of money that could 

be sent through MoneyGram at a Walmart location in the United States was $20,000 per day, but 

the limit for a single transaction was $10,000 until early 2018, when that amount was lowered to 

$8,000. Originally, the maximum amount that could be sent through a domestic 

Walmart2Walmart money transfer through Ria was $900, but that was raised to $2,500 in 

October 2016. Until sometime in 2018, generally, there were no set limits on the amount of 

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money that a customer could receive through MoneyGram or Ria in one day. In Canada, the 

maximum amount of a money transfer that can be sent from a Walmart location is $7,500 

(CAD), while the maximum amount that can be received at a Walmart location in Canada is 

$5,000 (CAD). Regardless of location, consumers sending a money transfer from a Walmart 

store must pay with cash or a PIN-based debit card. 

27. For many years, when initiating a money transfer at a Walmart location, the 

sender typically was required to complete a “send form,” which contained certain consumer 

fraud warnings. The send form required the sender to provide his or her name, physical address, 

and telephone number, the name of the recipient, and the state/province and country to which the 

money transfer was being sent. Repeat customers only had to provide their phone number (or 

rewards number) and were not required to complete the rest of the form because their 

information will automatically populate in Walmart’s point-of-sale system. In or around late 

2019, Walmart stopped requiring senders to complete send forms, but before completing their 

transactions, Walmart began providing senders with a printout containing consumer fraud 

warnings in small print. In some cases, consumers are not aware of this small print disclosure or 

do not even receive it until after their transfers are complete. 

28. For years, Walmart did not ask senders to present identification (“ID”) unless 

their transfers exceeded a certain dollar threshold set by Walmart’s providers. For example, 

MoneyGram required its agents, including Walmart, to record the sender’s ID information at 

$900 in the United States, while Western Union required its agents in Canada, including 

Walmart, to record the sender’s ID information at $1,000 (CAD). For money transfers of $3,000 

or more, in accordance with the Bank Secrecy Act (“BSA”), senders in the United States have 

also been required to provide their Social Security Number or Tax Identification Number, or if 

not available, alien ID or passport information to be recorded. Walmart did not begin requiring 

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its associates to verify and record the sender’s ID information for all transactions until late 

January 2018, and only did so because MoneyGram reduced its ID threshold to $1. 

29. In order to send a money transfer, consumers must pay a fee that varies depending 

on the platform (in person versus online), the destination, the amount, and the method of 

payment. Walmart also offers flat-fee money transfer services for consumers through 

Walmart2Walmart and Walmart2World money transfers, which Walmart touts as a lower-cost 

alternative. Walmart has earned millions of dollars in these fees to date. Consumers are 

provided with a unique reference number by Walmart to track their transfers. Typically, the 

money is available for pickup within minutes after the money transfer has been sent. 

30. For many years, before paying out a money transfer, Walmart’s providers 

required Walmart locations to have recipients (also referred to as receivers or beneficiaries) 

complete a “receive form” with the reference number, receive amount, recipient’s name, physical 

address, and telephone number, sender’s name, telephone number, and the city and state from 

which the transfer was sent. The recipient also was supposed to present his or her governmentissued photo ID for verification in receiving the transfer, although the Walmart location was only 

required to record the recipient’s ID at a certain dollar threshold. For example, for many years, 

Walmart was required to record the ID of a recipient who received a money transfer of $900 or 

more in the United States. In addition, when the recipient did not have an ID and the money 

transfer was less than a certain amount, such as $900, the sender sometimes had the option of 

using a preset answer to a test question. For money transfers of $3,000 or more, recipients in the 

United States also are required to provide their Social Security Number or Tax Identification 

Number, or if not available, alien ID or passport information to be recorded by the Walmart 

location. Beginning in or around May 2016, the ID threshold for recipients was lowered to $1, 

the test question was eliminated, and Walmart stopped using the receive forms. 

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31. Once the cash funds have been paid out to the recipient, fraud victims usually 

have not been able to get their money back, either from Walmart or its providers. For example, 

for many years, senders typically could not get their money back unless they had asked for a 

refund before the money transfer had been picked up. As a result of agreements that 

MoneyGram and Western Union reached with the FTC, as well as most of the states, between 

2016 and 2018, those refund policies have been expanded to provide refunds if the providers or 

their agents—including Walmart—have failed to follow certain anti-fraud policies and 

procedures, such as failing to provide the required consumer fraud warnings or to verify or 

accurately record IDs. 

Use of Walmart Money Transfers to Facilitate Fraud and Harm Consumers 

32. Walmart has provided an essential service to fraudulent telemarketers, sellers, and 

con artists by permitting them access to its providers’ money transfer systems at its locations 

while failing to have its own comprehensive and effective anti-fraud program, and, in some 

cases, failing to comply even with its providers’ anti-fraud policies and procedures. Exploiting 

this access to its full potential, perpetrators of mass marketing and imposter scams have received, 

and continue to receive, at Walmart locations, millions of dollars from victimized consumers, 

including many elderly consumers. 

33. Fraudulent telemarketers and con artists have preferred to use money transfers at 

Walmart stores to facilitate their scams because, among other reasons, there are many convenient 

locations from which victims can send the money. In addition, unlike many agents that use other 

forms of payments, such as money orders, for large payouts, Walmart pays recipients in cash, 

even for large-dollar transfers. Fraudsters also have been able to pick up money transfers within 

minutes and at multiple locations, and, oftentimes, the perpetrators have been afforded 

anonymity because either no IDs were required or fake IDs were provided. For example, money 

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transfers can be picked up at any location within a particular state or country; for many years, 

money transfers under $900 could be picked up without recipients having to present an ID; 

recipients have used fake names, addresses, and IDs; Walmart’s employees in numerous 

instances have not been properly trained, or have not been knowledgeable, regarding the policies 

or procedures that are required to detect and prevent fraud; some employees have failed to 

comply with the policies and procedures in paying out money transfers; and employees have 

sometimes been complicit in the frauds. In some cases, Walmart has violated its providers’ 

policies and procedures, while in others, Walmart has failed to implement and maintain its own 

effective policies or procedures to detect and prevent fraud. Walmart’s failures on this front 

often have made it easier for victims to unwittingly send money to fraudsters and for fraudsters 

to receive payments through money transfers at Walmart locations. At the same time, these 

failures have also made it more difficult for consumers and law enforcement to identify and 

locate the recipients of fraud-induced money transfers. 

34. For years, Walmart has been aware that criminal fraud rings, including those 

perpetrating telemarketing scams, have picked up fraud-induced money transfers at Walmart 

locations. For example, in May 2016, Walmart became aware that five individuals had been 

arrested in connection with an Internal Revenue Service (“IRS”) impersonation scam conducted 

over the telephone that bilked thousands of U.S. consumers out of millions of dollars through 

fraud-induced money transfers picked up at Walmart locations. Ultimately, at least fifteen 

individuals were indicted in connection with that scheme, most of whom have since pleaded 

guilty. See U.S. v. Caballero, No. 16-cr-0124 (E.D. Ark.), U.S. v. Caballero, No. 16-cr-0201 (D. 

Minn.), and U.S. v. Mirabal, No. 16-cr-0269 (N.D. Tex.); see also U.S. v. Pando, No. 17-cr-0046 

(N.D. Miss.), and U.S. v. Labra, No. 17-cr-0314 (D. Md.). In 2017, Walmart became aware of 

arrests in at least two other IRS impersonation scams that involved the extensive use of fake IDs 

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at Walmart locations. In one of those scams, four individuals were charged in connection with a 

scheme that used fake IDs to pick up $666,537 in money transfers from 784 victims from 

January through August 2017, often at Walmart locations, with another 6,530 transactions 

totaling $2,836,745 linked to the fake identities used by those “runners” (also known as money 

mules). U.S. v. Gohil, No. 17-cr-0212 (E.D. Wis.) (three of the defendants later pleaded guilty). 

In the other scam, two individuals pleaded guilty in connection with an India-based 

telemarketing scam, including one who later admitted to using 134 different fraudulent IDs to 

pick up over $1 million in fraud proceeds from September 2016 to May 2017, often at Walmart 

locations. U.S. v. Patel, No. 17-cr-0094 (E.D. Wis.). 

35. Criminal authorities across the United States have charged and obtained guilty 

pleas against other individuals in connection with mass marketing and telemarketing schemes 

that obtained millions of dollars in fraud-induced money transfers that were sent from or 

received at Walmart locations. See, e.g., U.S. v. Marcks, No. 19-cr-0315 (D. Nev.) (five 

individuals charged in connection with India-based telemarketing and email marketing imposter 

scam targeting elderly consumers in the U.S. from June 2015 to April 2017 that falsely claimed 

consumers had outstanding taxes, open collection accounts, or other liabilities that required 

immediate payments to avoid adverse action; at least two defendants have pleaded guilty to 

conspiring with others in this scheme; internal documents show that Walmart later became aware 

that this scheme’s runners picked up at least 874 fraud-induced transfers totaling over $545,000 

at Walmart locations); U.S. v. Parmar, No. 19-cr-0160 (E.D. Va.) (six individuals charged in 

connection with international telemarketing scam involving government imposter and loan 

scams, including two individuals who pleaded guilty to working with others to pick up millions 

of dollars in fraud-induced money transfers from U.S. consumers, often at Walmart locations, 

from at least March 2017 until April 2019); and U.S. v. Hines, No. 17-cr-1038 (N.D. Iowa) (six 

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individuals pleaded guilty to involvement in relative-in-need or “grandparent” telemarketing 

scam that used money transfers to bilk elderly consumers in the U.S. between December 2015 

and September 2016; Walmart documents show the scheme used Walmart locations to pick up 

fraud-induced transfers); see also U.S. v. Smith, No. 21-cr-0372 (M.D. Pa.) (two individuals 

charged and one pleaded guilty in connection with an advance-fee sweepstakes scam conducted 

from October 2016 to June 2018 in which Jamaica-based fraudsters contacted victims by 

telephone or through the Internet; the defendants regularly received fraud-induced money 

transfers from multiple Walmart locations, including from multiple Walmart locations in the 

same day); and U.S. v. Budhadev, No. 20-cr-0252 (M.D. Pa.) (one individual charged and 

pleaded guilty in connection with various India-based mass marketing schemes, including an 

advance-fee government grant scam, in which the fraudsters contacted victims by telephone or 

through the Internet; the defendant was charged with picking up over $500,000 in fraud-induced 

money transfers between October and December 2015, including over 300 money transfers 

totaling more than $407,000 from over 250 senders at seven Walmart locations). These schemes 

often involved suspicious money transfers for high-dollar amounts using fake IDs and/or money 

mules to pick up the proceeds of telemarketing and other frauds at Walmart locations. 

36. Consumers who use Walmart’s money transfer services are often not in a position 

to prevent fraud-induced transfers. By the time they come to Walmart to send money transfers, 

they already have been deceived by fraudulent schemes. Often, based on false promises or even 

fear of financial or legal consequences, they feel compelled to complete the transactions. Many 

consumers are not aware of the heightened risks associated with money transfers, such as a 

dramatically diminished possibility of fraud detection or transaction reversal as compared to 

other payment mechanisms, such as credit card transactions. 

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37. Walmart typically directs consumers to report fraud to its money transfer 

providers, which maintain databases of complaints and other reports they receive about fraud 

(hereinafter collectively “complaints”). For many years, those companies have shared 

complaints with Walmart about money transfers sent and/or received at its stores. Based on 

information in MoneyGram’s, Ria’s, and Western Union’s databases, between January 1, 2013 

and December 31, 2018, those companies received at least 226,679 complaints about fraudinduced money transfers that were sent from or received at a Walmart location, totaling at least 

$197,316,611 (including fees). Of those complaints, MoneyGram received at least 176,672 

complaints totaling at least $159,594,760, Ria received at least 43,603 complaints totaling 

approximately $32,741,213, and Western Union received at least 6,404 complaints totaling 

approximately $4,980,638. The average individual consumer fraud loss reflected by those 

complaints was approximately $870 from 2013 through 2018. These complaints represent only a 

small percentage of the actual fraud perpetrated through money transfers sent from or received at 

Walmart locations. 

38. Walmart is responsible for a significant proportion of the complained-about fraudinduced money transfers flowing through its providers’ money transfer systems. In fact, 

historically, Walmart has been responsible for more complaints about fraud-induced money 

transfers than any other agent worldwide. For example, for MoneyGram, between January 1, 

2013 and December 31, 2018, Walmart was responsible for approximately 56 percent of all 

complaints about fraud-induced money transfers through MoneyGram worldwide. For Ria, from 

2015 through 2018, Walmart was responsible for between approximately 80 to 93 percent of all 

of the complaints about fraud-induced money transfers through Ria worldwide. For Western 

Union, between January 1, 2013 and December 31, 2018, Walmart was responsible for 

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approximately 22 percent of all complaints about fraud-induced money transfers in Canada, 

where Walmart is one of its agents. 

Walmart’s Role in Detecting and Preventing Fraud and Telemarketing-Related Transfers 

39. As an agent dealing directly with consumers who send and receive money 

transfers through one or more providers, Walmart is well positioned to detect and prevent fraudinduced and telemarketing-related transfers. 

40. Walmart’s role as a large agent offering multiple money transfer services makes it 

integral to that effort because Walmart controls whether to: implement and maintain policies and 

procedures concerning fraud-induced and telemarketing-related transfers, educate and train its 

employees on consumer fraud, supervise its employees to ensure that they are complying with 

anti-fraud policies and procedures, provide fraud warnings to consumers, monitor and investigate 

money transfer activity to identify unusual or suspicious activity, and take actions to prevent 

consumers from sending or receiving fraud-induced money transfers, including those related to 

telemarketing. Indeed, Walmart is in fact obligated to do many of these things by contract or 

court order. 

41. Walmart has entered into written agreements with MoneyGram, Ria, and Western 

Union to provide money transfer services. These agreements require Walmart to comply with its 

providers’ policies and procedures, maintain records of money transfers it processes, and train its 

employees about compliance and the prevention of fraud and money laundering involving money 

transfer services at its locations. These agreements also require Walmart to allow only 

authorized persons to access their systems and to prevent unauthorized use by providing access 

credentials, including passwords. Walmart’s agreement with MoneyGram, for example, requires 

it to maintain its own effective policies and procedures designed to detect and prevent consumer 

fraud, monitor all transactions conducted by Walmart, investigate activity consistent with money 

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laundering and financial crimes, and take measures to prevent its services from being used to 

facilitate fraud and money laundering. Walmart’s agreement with Western Union requires it to 

monitor its personnel’s performance of responsibilities under the contract and to notify Western 

Union and remedy any deficiencies. Walmart’s agreement with Ria provides that both parties 

are responsible for their own fraud prevention programs and Walmart also is responsible for 

training its employees and assumes full responsibility for supervising its employees’ conduct. 

Under their agreements, Walmart’s providers have the right to audit Walmart’s records, 

compliance, and training of employees, but only with advance written notice. Walmart has 

commission, fee, and bonus arrangements with its providers that are based on the transactions it 

processes. 

42. Since in or around October 2009, MoneyGram and its agents, including Walmart, 

were subject to the Stipulated Order for Permanent Injunction and Final Judgment in FTC v. 

MoneyGram, No. 09-cv-6576 (N.D. Ill. Oct. 19, 2009) (“2009 Order”). Among other things, the 

2009 Order enjoined violations of any provision of the TSR, as promulgated or later amended, 

by providing substantial assistance or support to any seller or telemarketer, and also enjoined 

MoneyGram and its agents from failing to establish, implement, and maintain a comprehensive 

anti-fraud program designed to protect U.S. and Canadian consumers from fraud-induced money 

transfers worldwide. The 2009 Order’s requirements included, but were not limited to, providing 

warnings to consumers, providing appropriate and adequate ongoing education and training on 

consumer fraud at all locations, taking reasonable steps to monitor and investigate activity at 

locations to detect and prevent fraud, taking reasonable steps to identify locations that are 

involved or complicit in frauds, and routinely reviewing and analyzing data regarding money 

transfer activities that are unusual or suspicious. On February 1, 2010, Walmart acknowledged 

receipt of the 2009 Order. In several presentations made to FTC staff, beginning in or around 

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April 2010, Walmart representatives committed to developing a plan to reduce fraud that would 

focus on associate training and consumer education. Walmart also represented that it had 

already implemented a comprehensive anti-fraud program. 

43. On December 14, 2015, the FTC published a notice that it had adopted 

amendments to the TSR, including a prohibition against using “cash-to-cash” money transfers 

for outbound and inbound telemarketing transactions. 80 Fed. Reg. 77,520 (Dec. 14, 2015). 

This amendment became effective on June 13, 2016, and it prohibits the use of such money 

transfers for goods or services offered or sold through telemarketing or charitable contributions 

solicited or sought through telemarketing. 

44. In or around January 2017, Western Union and its agents, including Walmart, 

became subject to the Stipulated Order for Permanent Injunction and Final Judgment in FTC v. 

Western Union, No. 17-cv-0110 (M.D. Pa. Jan. 19, 2017) (“2017 Western Union Order”). Under 

that order, Western Union and its agents must establish, implement, and maintain a 

comprehensive anti-fraud program designed to protect consumers worldwide by detecting and 

preventing fraud-induced money transfers. The order’s requirements also include, but are not 

limited to, providing warnings to consumers, appropriate and adequate education and training to 

frontline employees, monitoring of activity to prevent fraud-induced money transfers, 

investigation of and disciplinary action against agents, and adequate systematic controls to detect 

and prevent fraud-induced money transfers. The order also addresses compliance with the TSR 

Amendment’s prohibition of cash-to-cash money transfers and requires Western Union and its 

agents to identify, prevent, and stop cash-to-cash money transfers initiated or received in the U.S. 

from being used as a form of payment in telemarketing transactions. These requirements include 

asking consumers before they transfer money whether their transfers are to pay for goods or 

services offered or sold through telemarketing and declining to process such money transfers. 

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Finally, the order mandates that Western Union and its agents warn consumers that it is illegal 

for any seller or telemarketer to accept money transfers as payment for goods or services sold 

through telemarketing. On January 27, 2017, Western Union provided Walmart with a copy of 

the 2017 Western Union Order. 

45. In November 2018, a Stipulated Order for Compensatory Relief and Modified 

Order for Permanent Injunction (“Modified Order”) was entered against MoneyGram. That 

Modified Order expanded the anti-fraud requirements of the 2009 Order to protect consumers 

worldwide and has similar requirements to the 2017 Western Union Order. It also required 

MoneyGram to pay $125 million in compensatory relief. On December 5, 2018, Walmart 

acknowledged receipt of that order. 

46. Walmart’s agreements with its providers require it to comply with any orders, 

judgments, or decrees that apply to its providers, as well as any applicable laws. As an MSB, 

Walmart is required by the BSA to have an effective AML program to guard against money 

laundering, including, but not limited to, guarding against the flow of illicit funds, such as funds 

derived from fraud. 

47. Even in the face of these independent obligations to detect and prevent consumer 

fraud and money laundering, as well as telemarketing-related money transfers, for many years, 

Walmart has failed to: (a) establish, implement, and maintain a comprehensive and effective 

anti-fraud program designed to detect and prevent consumer fraud; (b) properly train and ensure 

that its employees are knowledgeable about anti-fraud and AML policies and procedures 

designed to prevent consumer fraud; (c) adequately oversee and supervise employees responsible 

for providing money transfer services at its locations; (d) adequately monitor and investigate 

unusual or suspicious activity at its locations to prevent fraud-induced money transfers; (e) stop 

money transfers that Walmart or its employees should know or suspect are fraud-induced; (f) 

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adequately collect, record, and report consumer fraud involving money transfers at its locations; 

and (g) take other reasonable steps to prevent fraudulent telemarketers, sellers, and con artists 

from using money transfer services offered by Walmart to perpetrate their frauds. In some cases, 

Walmart has failed to adopt effective policies concerning these practices, while in others, 

Walmart has failed to adhere to, or has violated, its providers’ policies and procedures or its own 

anti-fraud and AML programs, policies, and procedures. 

WALMART HAS REGULARLY PROCESSED FRAUDULENT AND 

TELEMARKETING-RELATED MONEY TRANSFERS 

48. Perpetrators of many different types of mass marketing and imposter scams have 

relied on money transfer systems, including MoneyGram’s, Ria’s, and Western Union’s systems, 

as a means of fraudulently obtaining money from consumers around the world—especially U.S. 

consumers. The types of scams include, but are not limited to, online or Internet purchase scams, 

person-in-need, grandparent, and emergency scams, Good Samaritan or charity scams, 

investment scams, employment scams, rent scams, romance scams, advance-fee loan scams, debt 

relief scams, lottery, prize, and sweepstakes scams, government imposter and utility scams, and 

cyber or malware scams. All of these scams operate deceptively in violation of Section 5 of the 

FTC Act, and many of the scams also involve fraudulent telemarketing in violation of the TSR. 

In these scams, consumers often are instructed over the telephone, through text message, by 

email, or over the Internet to send money transfers. The telemarketers and con artists use false or 

misleading statements to induce consumers either to pay for purported goods or services, such as 

loans or large cash awards, or to make payments as a result of purported circumstances, such as 

emergencies, that do not exist. 

49. Victims of fraud-induced money transfers often send their money transfers from 

Walmart locations. In some cases, fraudsters even direct consumers to send their money 

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transfers from a Walmart location. In many cases, older consumers (ages 65 and older) have 

been financially exploited by sending money transfers in connection with common telemarketing 

scams, such as grandparent scams, Good Samaritan scams, lottery or prize scams, and romance 

scams, from Walmart locations. The average loss suffered by older consumers is usually greater 

than for younger consumers. In addition, perpetrators of the scams, or those acting on their 

behalf, including fraud rings and money mules, frequently collect the proceeds of the frauds from 

Walmart locations, and in some instances, those individuals have even been employees of 

Walmart. 

50. MoneyGram’s, Ria’s, and Western Union’s records show that Walmart has been 

responsible for a substantial amount of fraud-induced money transfers through their money 

transfer systems. As Walmart is aware, many fraud-induced money transfers described in those 

records involve telemarketing scams. Between January 1, 2013 and December 31, 2018, 

Walmart locations were responsible for processing at least $197,316,611 in money transfers that 

were the subject of complaints and over $1.3 billion money transfers that were related to those 

complaints and therefore could have been fraud-induced. 

a. Information from MoneyGram indicates that between January 1, 2013 and 

December 31, 2018: 

1) MoneyGram received a total of at least 176,672 complaints 

reporting losses of $159,594,760 (including fees) involving 

Walmart. 

2) An additional 695,404 money transfers with total losses of 

$376,322,686 (including fees) were linked to complaints received 

by MoneyGram about fraud-induced money transfers involving 

Walmart.

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3) Although Walmart has accounted for approximately 26 percent of 

MoneyGram’s money transfers based on volume and 

approximately 24 percent based on dollar amount, Walmart was 

responsible for sending or paying out approximately 56 percent of 

all complained-about fraud-induced money transfers worldwide 

through MoneyGram.

b. Information from Ria indicates that between April 24, 2014 and December 

31, 2018: 

1) Ria received a total of at least 43,603 complaints reporting losses 

of $32,741,212.93 (including fees) that were sent from or received 

at a Walmart location. 

2) An additional 2,056,697 money transfers totaling $878,383,329.49 

(without fees) were transactions conducted by senders or recipients 

of fraud-induced money transfers, and therefore, were potentially 

related to fraud.

3) Walmart has accounted for approximately 36 percent of Ria’s 

money transfers based on volume and approximately 27 percent of 

Ria’s money transfers based on dollar amount, but in 2017 alone, 

Walmart accounted for approximately 93 percent of Ria’s fraud 

cases based on volume and approximately 89 percent of Ria fraud 

cases based on dollars. In 2018, Walmart accounted for 

approximately 87 percent of Ria’s fraud cases based on volume 

and approximately 90 percent of Ria fraud cases based on dollars.

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c. Information from Western Union indicates that between January 1, 2013 

and December 31, 2018: 

1) Western Union received a total of at least 6,404 complaints 

reporting losses of $4,980,638.36 (including fees) involving 

Walmart in Canada, including 1,889 complaints totaling 

$1,228,446 about transfers that originated from or were paid out in 

the United States.

2) An additional 146,213 money transfers totaling approximately 

$93,270,569.72 (including fees) were identified by Western Union 

as being related to senders or receivers of confirmed fraud 

transactions, transactions considered to be potential fraud after an 

investigation of a Walmart location, or transactions associated with 

risky typologies associated with consumer fraud scams.

3) Altogether, Walmart was responsible for sending or paying out 

approximately 22.1 percent of all complained-about fraud-induced 

money transfers in Canada through Western Union. 

51. After the maximum dollar amount for Walmart2Walmart money transfers 

increased from $900 to $2,500 in October 2016, there was a significant increase in fraud 

transactions involving Ria. In fact, between August 2016 and August 2017, the volume of fraud 

involving Walmart2Walmart money transfers increased by 374 percent, even though the 

transaction volume of such transfers had only increased by 54 percent. In September 2016, a 

month before Ria increased the limit of a Walmart2Walmart transaction, Ria received 574 fraud 

reports totaling $293,249.87 for that month. Six months later, in March 2017, Ria received 

1,336 fraud reports totaling $1,318,138.19—more than four times the reported fraud amount 

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from September 2016. Moreover, after increasing the maximum dollar amount of a 

Walmart2Walmart transfer, the number of annual fraud reports to Ria more than doubled 

between 2016 and 2017 from 8,112 to 16,922 fraud cases, and the amount of reported fraud loss 

more than tripled from $4,659,930.43 to $14,371,085.60. Those fraud report numbers remained 

high throughout 2017, with the average monthly fraud volume at 1,410 complaints totaling 

$1,197,590.47 in losses. By March 2018, the monthly reported fraud volume involving 

Walmart2Walmart transfers reached a peak of 1,751 complaints totaling $1,578,412.95. 

52. In March 2017, at least 4,974 fraud-induced money transfers totaling 

$5,081,268.62 were reported to MoneyGram and Ria concerning transactions that were either 

sent from or paid out at a Walmart location, or both. These were the largest monthly totals of 

reported fraud-induced transfers since February and March 2016, when MoneyGram experienced 

technical problems with its interdiction system, as described below. 

53. For many years, Walmart also has been aware of consumer fraud involving its 

stores, including particular locations that had very high levels of consumer fraud and suspicious 

activities. In fact, MoneyGram and Western Union have provided information to Walmart about 

certain locations in the United States and Canada that had fraud rates of more than 25 percent, 50 

percent, or even 75 percent of their money transfer activity (based on the number or dollar 

amount of transactions) when taking into account confirmed fraud and linked or potential fraud. 

Although Ria did not provide Walmart with similar information about fraud rates at its locations 

based on confirmed and linked or potential fraud, it did provide Walmart with information about 

confirmed fraud at locations, as well as unusual or suspicious activity, such as transactions that 

had bad addresses, including addresses that were P.O. boxes, incomplete, or listed as 

“anywhere,” “unknown,” or “not given.” 

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54. In May 2018, Walmart conducted an analysis of Walmart locations in the United 

States that would be classified as an Elevated Fraud Risk Agent Location (“EFRAL”) under the 

2017 Western Union Order, and determined that, from January 2017 through January 2018, there 

were 317 instances in which Walmart stores met the EFRAL criteria, including 12 stores that had 

15 or more complaints in a two-month period. The remaining 305 stores had five or more 

complaints that amounted to five percent or more of money transfers received at those locations. 

Those 317 separate instances involved 190 unique Walmart store locations because some of the 

stores had met the criteria more than once. 

Walmart has Failed to Effectively Detect and Prevent Fraud-Induced and TelemarketingRelated Money Transfers 

55. For many years, perpetrators of frauds, including fraudulent telemarketers, sellers, 

and con artists, have accessed and exploited Walmart’s money transfer services, and Walmart’s 

locations have played an integral role in the scams. Walmart’s locations have been more 

susceptible to fraud-induced money transfers in part due to the thousands of associates 

authorized to provide money transfer services at its locations, the high turnover rate of 

associates, heavy customer traffic, and/or various shifts of associates working at a single 

location. In addition, as a dual agent for MoneyGram and Ria in the United States, there is a 

heightened risk of consumer fraud at its locations because consumers can send and receive 

money transfers through two different money transfer companies without being detected by those 

companies. Walmart has been, or should have been, well aware of these facts. 

56. Walmart nonetheless has failed to take basic and important steps to address 

consumer fraud, including by failing to implement and maintain effective policies and 

procedures to detect and prevent fraud, provide education and training that included clear 

directions to its employees about detecting and preventing consumer fraud, supervise and 

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oversee its employees to ensure that they are complying with anti-fraud and AML policies and 

procedures, routinely provide fraud warnings to consumers, adequately monitor and investigate 

money transfer activity to determine if there is any unusual or suspicious activity, and take 

effective actions to prevent consumers from sending or receiving fraud-induced money transfers, 

including those related to telemarketing. 

57. In many instances, Walmart’s locations have not complied with Walmart’s 

providers’ anti-fraud or AML policies and procedures. Walmart also has not taken adequate and 

timely steps to address the deficiencies and inconsistencies in its own anti-fraud program, 

policies, and procedures and to address consumer fraud at its locations. In addition, in some 

cases, Walmart has had corrupt or complicit employees at its locations that have facilitated the 

payments of fraud-induced money transfers. As a result of Walmart’s failure to implement and 

maintain a comprehensive anti-fraud program to detect and prevent consumer fraud, it has played 

a significant role in sending and receiving fraud-induced money transfers through its providers’ 

money transfer systems. These failures have caused many millions of dollars in consumer 

losses, without providing benefits to consumers or competition that has outweighed the harm 

suffered by defrauded consumers. 

Walmart has Failed to have a Comprehensive Anti-Fraud Program 

58. For many years, Walmart has failed to establish, implement, and maintain its own 

comprehensive anti-fraud program, policies, procedures, and controls designed to detect and 

prevent consumer fraud even though Walmart has been aware that there was a substantial 

amount of fraud-induced money transfers moving through the money transfer systems at 

Walmart’s locations. Until in or around November 2014, Walmart did not even have a written 

anti-fraud and consumer protection program documenting its policies and procedures for 

detecting and preventing consumer fraud at its locations. 

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59. Even after establishing a written anti-fraud program, in some cases, Walmart 

violated its own program requirements. For example, although Walmart’s anti-fraud program 

required stores that had been identified by its providers as having higher incidents of fraud 

received at their locations to complete “Receive Fraud Training” within seven days of when the 

training was assigned, in many cases, those locations did not comply with that requirement. In 

some cases, the training required by MoneyGram at particular locations was not completed for 

months after Walmart’s policies required it. In addition, even though Walmart’s anti-fraud 

program required Walmart stores to have certain consumer education and awareness materials, 

including consumer fraud warnings and pamphlets, in many cases, Walmart locations have not 

complied with those requirements. 

60. For many years, Walmart’s anti-fraud program also had no written procedures for 

its associates to prevent suspected or known fraud-induced money transfers from being paid out 

at its locations. For example, in Walmart’s July 2014 and November 2017 programs, although 

there were written procedures on how Walmart associates should respond when they suspected 

that senders of money transfers may be victims of fraud, there were no written procedures for 

how Walmart associates should respond when they suspected that receivers of money transfers 

may be potential fraudsters. 

61. On April 19, 2017, MoneyGram conducted a Home Office Review of Walmart’s 

anti-fraud program and found that: (1) Walmart had not effectively prevented fraud transactions; 

(2) Walmart had not properly completed required information on transaction records; and 

(3) Walmart had not reported, filed, or referred all Suspicious Activity Reports (“SARs”) as 

required. In an August 10, 2017 letter to Walmart, MoneyGram explained that the main concern 

for the finding that Walmart had not effectively prevented fraud transactions was because, “at the 

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policy level,” Walmart was “not reject[ing] potential consumer fraud related transactions on the 

receive end.” 

Walmart’s Deficient Practices Related to Receive-Side Fraud 

62. According to Walmart’s written anti-fraud program, Walmart’s goal was “to 

educate, detect, investigate, respond, and deter consumer fraud against our customers.” Despite 

that stated goal, Walmart failed to implement practices designed to effectively detect and prevent 

fraud-induced money transfers received at its stores, and instead assisted and facilitated fraud by 

adopting practices that were harmful to consumers. For example, in 2015, Walmart adopted a 

practice of not training its employees to deny or reject payouts to suspected fraudsters at the 

point of sale. Although Walmart trained its employees to refuse to send money transfers if they 

believed the sender was a victim of fraud (referred to as “send-side fraud”), it did not direct its 

employees to deny or reject payouts to receivers of suspected fraud-induced money transfers 

(referred to as “receive-side fraud”). Instead, Walmart’s training instructed employees not to 

deny those transfers, but instead to report them by faxing a paper Money Services Activity 

Report (“MSAR”) to Walmart’s Home Office. In May 2017, Walmart replaced this paper 

MSAR system with an Electronic Money Services Activity Report (“eMSAR”), as described 

below. In addition, the Quick Reference Guide for employees that was in use from in or around 

November 2016 until sometime in 2018, stated, “If you suspect fraud, complete the transaction,” 

and report it to MoneyGram and Walmart’s Home Office. Walmart adopted this practice despite 

knowing that once the money transfers were paid out to suspected fraudsters, fraud victims 

typically could not get their money back. Walmart continued this practice despite being told by 

MoneyGram, after MoneyGram learned about this practice in 2015, that it expected Walmart and 

its employees not to pay out money transfers to suspected fraudsters. 

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63. By failing to have consistent policies, procedures, and practices requiring its 

employees at its stores to deny and not pay out money transfers to suspected fraudsters, 

Walmart’s locations were more susceptible to consumer fraud, thereby substantially assisting 

fraudsters, including telemarketers and sellers, and causing significant financial injury to victims 

of fraud-induced money transfers. From September 2015 through October 2018 and again from 

December 2018 through May 2019, Walmart’s receive-side fraud rate by volume for domestic 

transfers through MoneyGram was higher than the rates for the rest of MoneyGram’s agent 

network in the United States. In March 2017 alone, Walmart’s fraud rate for receive-side fraud 

based on the dollar value was approximately three to four times higher than the rest of 

MoneyGram’s U.S. agents. 

64. Walmart did not begin to adjust its practice of not training its employees to reject 

suspected receive-side fraud transfers at the point of sale until May 2017—after MoneyGram 

began suspending Walmart locations for the first time. Even then, this remedial training was 

only provided to some Walmart employees at problematic locations that MoneyGram required to 

have additional training because the locations had been suspended or identified as having higher 

incidents of consumer fraud. 

65. Walmart’s remedial training included instructions about the company’s new 

eMSAR process for canceling and reporting transactions to Walmart’s Home Office, which did 

not effectively address Walmart’s handling of receive-side fraud. For example, from May 

through at least October 2017, Walmart’s remedial training instructed associates to reject certain 

suspected receive-side fraud transactions at the point of sale by using the “Scam” option in 

eMSAR—but the eMSAR menu interface contradicted this, stating instead that the option was to 

be used only for fraud against Walmart customers who may be victims of a scam or against 

Walmart itself, rather than for potential fraudsters. In addition, although there was an option in 

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eMSAR for “Suspicious Behavior During a Money Transfer Receive,” the eMSAR menu 

indicated that associates should only use that option when the customer had received more than

five different transactions in a single day—five fraud-induced money transfers per day would not 

qualify. And even worse, the direction in eMSAR was only to report, but not to cancel, those 

transactions. 

66. In or around November 2017, Walmart finally changed its remedial training, as 

well as its eMSAR menu, to instruct associates to use the “Suspicious Behavior During a Money 

Transfer Receive” to cancel certain suspicious transactions on the receive side at the point of 

sale. However, Walmart still directed its associates to use that option only in two very limited 

circumstances: (1) when a customer had multiple high-dollar amount receives during the same 

day or multiple times a week, or (2) when a customer presented different IDs during different 

visits, such as IDs with different names. The only other eMSAR option that could apply to 

suspected receive-side fraud, “Conversation (Customer said something suspicious to you or 

another customer),” only instructed employees to report the transaction to Walmart’s Home 

Office, but did not instruct them to cancel it. 

67. From May 2017 until late 2018, regardless of whether associates used the “Scam” 

or “Suspicious Behavior During a Money Transfer Receive” option to cancel transactions, those 

eMSAR options only reported the transactions to Walmart’s Home Office. That meant suspected 

fraudsters could go to another Walmart employee or to a different location to pick up their 

transfers, because information about those customers and their cancelled transactions were not 

necessarily reported to MoneyGram or Ria in a timely fashion. Although Walmart’s remedial 

training at this point also instructed associates to call the provider (MoneyGram or Ria) to report 

their suspicions after the customer left, so that the provider could systematically block the 

transfer from being picked up elsewhere, Walmart associates often failed to do so. 

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68. In addition, Walmart’s regular annual training and resource materials for 

employees in Walmart’s Customer Service Desks and MoneyCenters gave contradictory 

guidance regarding the handling of receive-side fraud—they continued to direct employees not to 

deny and to “complete” the suspected fraud transactions, and only then to report them as 

suspicious. Walmart’s annual training for salaried managers also provided more limited content 

on consumer fraud overall and only focused on refusing to send, but not refusing to pay out, 

potential fraud-induced money transfers. 

69. Walmart did not update its annual training to instruct associates that if they “have 

identified a potential fraudster,” they should refuse the transaction and report it using the 

eMSAR process until at least late 2018. Even then, however, Walmart still gave its associates 

mixed signals, telling them elsewhere in the training that they should not deny a suspicious 

transaction when a customer has received “large dollar amounts, multiple times a day,” and he 

“appears nervous and has gone to different registers each time.” Because this was an annual 

training, moreover, many Walmart associates did not have to complete this training until 

sometime in 2019. 

70. Although the updated annual training for both associates and supervisors 

instructed that “managers and supervisors should not override your decision to reject a financial 

service transaction when you suspect the customer may be a victim of a fraud or scam,” it did not 

provide the same instruction for a payout to a potential fraudster. The updated annual training 

for salaried managers also continued to focus only on refusing the transactions of customers who 

may be victims of fraud. Therefore, this updated annual training continued to provide 

inconsistent instructions for employees regarding the handling of suspected receive-side fraud. 

71. It was only in late 2018 that Walmart’s eMSAR process became automated so 

that it could transmit information directly to Walmart’s providers without Walmart associates 

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having to make a phone call to the provider to report suspected fraudsters. Despite that, in many 

cases, the eMSAR process for preventing payouts of fraud-induced money transfers and training 

has continued to be ineffective because (1) Walmart’s annual training has provided inconsistent 

instructions on the handling of suspected receive-side fraud; (2) as described more fully below, 

Walmart has failed to ensure that its employees are properly trained and knowledgeable about 

the use of Walmart’s eMSAR process for stopping suspected receive-side fraud; (3) Walmart’s 

eMSAR menu options relating to receive-side fraud continue to be too limited, and include only 

such circumstances as multiple high-dollar money transfers received during the same day or over 

multiple weeks, or customers presenting different IDs during different visits; and (4) managers at 

Walmart locations have sometimes overridden associates’ decisions not to complete transfers 

even when associates have detected unusual or suspicious activity. As of at least August 2018, 

Walmart also had not implemented the eMSAR process at its locations in Mexico even though it 

was known to be one of the top five destinations for international fraud-induced money transfers. 

72. For many years, despite Walmart’s awareness that its locations have been used by 

known and suspected fraudsters to receive funds for scams, many of which have been executed 

through telemarketing, Walmart did not routinely train or instruct its associates to ask consumers 

receiving suspicious money transfers questions about the nature or purpose of their money 

transfers. Since the TSR Amendment went into effect in June 2016, Walmart also has not 

trained or instructed its associates to ask questions about whether consumers are receiving funds 

as payments for goods or services sold over the phone or for charitable contributions solicited or 

sought over the phone.

Walmart’s Deficient Practices Related to Send-Side Fraud 

73. Walmart also has failed for many years to effectively prevent consumers from 

sending fraud-induced money transfers, including those related to fraudulent telemarketing sales 

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and illegal telemarketing payments, from Walmart locations. Despite Walmart’s awareness that 

its locations were often used to send fraud-induced money transfers, for years, Walmart failed to 

provide clear and consistent instructions to its associates in its annual and remedial training, as 

well as in some of its resource materials, about the necessary steps to effectively report and stop 

those transfers. As a result of Walmart’s lax practices, in many cases, it has failed to prevent 

senders of fraud-induced money transfers, particularly the elderly, who are frequently defrauded 

through telemarketing schemes, from being victimized in a variety of scams, including, but not 

limited to, grandparent scams, Good Samaritan scams, lottery or prize scams, and romance 

scams. In some cases, fraudsters have even directed consumers to send their money transfers 

from Walmart locations due to Walmart’s lack of safeguards. 

74. In many cases, Walmart has failed to take adequate measures to prevent 

consumers from sending money transfers that have characteristics indicative of fraud, such as 

multiple money transfers in relatively short periods of time, transfers to high-risk countries 

known for fraud, transfers in amounts that far exceed the average money transfer, and transfers 

to different individuals. For example, from February to March 2017, Walmart sent 52 transfers 

totaling $51,000 for one potential victim of elder financial exploitation to seven different 

receivers in Ghana and the United States. Similarly, in March to April 2017, Walmart sent 33 

transfers totaling $54,550 for another such victim to a recipient in Ghana. Only after these 

numerous suspicious transfers and huge dollar losses were these matters finally referred to law 

enforcement and Walmart’s providers. From May to July 2017, moreover, Walmart sent 42 

transfers totaling $71,235.16 for another customer to ten different receivers in Ghana, the United 

States, and Turkey before Walmart finally referred the matter to law enforcement and the 

provider after receiving multiple referrals from Walmart associates. According to one referral 

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from a Walmart associate, the customer indicated he was sending the money to buy millions of 

dollars in gold. 

75. In many cases, Walmart locations have also not provided required warnings to 

senders about common money transfer frauds sent or received through its stores. For example, 

even though FTC orders have required Walmart to use send forms that include a consumer fraud 

warning on the front page, in some cases, Walmart stores were missing the required send forms, 

or have used send forms that omitted the required consumer fraud warnings. In other cases, 

Walmart stores have not displayed consumer fraud warning signs or had consumer fraud 

brochures or pamphlets available. For example, in a presentation provided to Walmart in 

October 2019, Ria expressed concern that 39 percent of the Walmart stores it visited between 

January and August 2019 were missing fraud awareness materials, and it also noted that 24 

percent of the stores were missing send forms. 

76. Signs and send-form warnings alone are not enough, however, because consumers 

are not generally aware of the risks associated with money transfers, including the possibility 

that recipients can use false information or fake IDs to pick up money transfers. Despite being 

well aware of these risks, Walmart for years failed to take adequate steps to address them. Until 

at least March 2019, Walmart did not even take steps to ensure that its associates asked senders 

questions about whether their transfers were related to telemarketing or warned them about the 

fact that the TSR prohibits cash-to-cash money transfers as a form of payment for telemarketing 

transactions. Since then, in some cases, Walmart’s employees still do not ask senders whether 

their transfers are related to telemarketing or provide them with a clear and conspicuous warning 

before their transfers are completed that the TSR prohibits cash-to-cash money transfers related 

to telemarketing. 

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Walmart has Failed to Properly Train its Employees about Anti-Fraud and 

AML Policies and Procedures

77. Walmart and its providers have historically recognized that employees 

responsible for processing money transfers are the first line of defense in detecting and 

preventing consumer fraud, and Walmart’s providers have relied on Walmart to train its own 

employees in the policies and procedures required for detecting and preventing fraud. Although 

Walmart has long been aware of the importance of training employees responsible for providing 

or supervising money transfer services, it has failed to ensure that its employees are properly 

trained and are sufficiently knowledgeable about anti-fraud and AML policies and procedures. 

These employees may perform up to hundreds of thousands of dollars in financial transactions 

for consumers during a single shift. On numerous occasions, Walmart also has failed to 

promptly provide mandatory consumer fraud training as a remedial action for all employees at its 

high or higher fraud locations identified by its providers. For years, although MoneyGram 

required Walmart to provide remedial training to employees at high-fraud locations, Walmart 

failed to ensure that all employees at those locations had promptly received the required training. 

78. Walmart’s written policy, as well as Walmart’s contractual obligations with its 

providers, recognize the importance of training and require that all Walmart employees 

responsible for providing money transfer services receive initial and ongoing training. Walmart 

has primarily provided this training through annual computer-based learning. For many years, 

however, Walmart has failed to ensure that its employees responsible for providing money 

transfer services have taken the required training, are up to date on their training, or taken 

relevant training before providing money transfer services. For example, until at least September 

2015, Walmart did not even begin providing required training for the tens of thousands of 

secondary employees, who fill in for the primary employees responsible for providing money 

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transfer services. Moreover, Walmart’s Home Office did not have the ability to assign all of the 

relevant training relating to providing money transfer services to its secondary employees at 

Walmart locations until sometime in mid to late 2018. 

79. For many years, Walmart’s annual training for associates, supervisors, and 

managers with responsibilities for providing money transfer services have included limited 

information about detecting and preventing consumer fraud involving money transfers. For 

example, Walmart’s annual training, which takes between 20 to 45 minutes to complete, has 

primarily covered AML topics, while providing only limited directions on the handling of 

suspected fraud-induced money transfers. As described above, for many years, Walmart’s 

annual trainings did not even direct its associates to reject paying out money transfers if they 

suspected that the customers were fraudsters. In addition, Walmart’s trainings for its managers 

provided very little information about detecting and preventing fraud-induced money transfers. 

80. Despite receiving advance notice from its providers that they were going to be 

conducting compliance reviews or audits of certain Walmart locations, for many years, the 

providers have found that Walmart’s employees lack the proper training and knowledge about 

anti-fraud and AML policies and procedures relating to money transfers, including with respect 

to detecting and preventing fraud, accurately recording customers’ biographical information and 

IDs, and reporting, stopping, or otherwise addressing suspicious activities at those locations. 

81. A 2014 audit conducted by MoneyGram found that numerous Walmart locations 

had untrained or undertrained employees providing or supervising money transfer services in 

Walmart’s Customer Service Desks and MoneyCenters. MoneyGram informed Walmart that an 

audit of 397 Walmart locations 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 them were secondary employees who had never taken the required training. 

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Walmart’s internal documents indicate that MoneyGram’s 2014 audit found that overall, 39 

percent of Walmart locations had untrained primary employees and 60 percent had untrained 

secondary employees. 

82. Even after Walmart implemented a new audit preparation protocol in early 2015, 

which involved corporate communications, conference calls, and webinars with the stores in 

advance of audits, Walmart still continued to have untrained or undertrained employees who 

provided, or supervised the provision of, money transfer services. For example, in March 2015, 

MoneyGram identified a Walmart store in Houston, Texas as having the largest number of 

untrained employees ever found in a MoneyGram audit. By May 2015, Walmart was aware that 

at least 15 percent of its stores continued to have untrained or undertrained employees working 

in, or supervising, money transfer services. Moreover, between January 2015 and July 2016, 

MoneyGram’s review of 323 Walmart locations across the country revealed that 61 (or 

approximately 19 percent) of them had employees who had not completed either initial or 

ongoing compliance-related training. Similarly, from July through September 2017, 

MoneyGram’s reviews of 87 stores in 14 states revealed that 30 stores (or 34 percent) had 

employees who had not completed ongoing compliance-related training. Ria’s reviews of stores 

resulted in similar findings. For example, in September and October 2018, Ria’s reviews of 95 

stores revealed that Walmart had at least 600 associates at those locations who were past due on 

training. 

83. Although Walmart recognized the need to implement point-of-sale register 

lockouts as a control to prevent employees who were not properly trained or knowledgeable 

about anti-fraud and AML procedures from processing money transfers, it took several years—

until at least in or around mid to late 2018—for Walmart to finally implement the lockouts. 

However, even with the lockouts, Walmart’s providers have continued to find locations that had 

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untrained, undertrained, or unknowledgeable employees providing money transfer services. For 

example, in July 2019, Ria’s reviews of 48 Walmart locations in four states continued to uncover 

associates with incomplete training and insufficient knowledge on a variety of anti-fraud and 

AML topics and procedures. Ten of those stores had unsatisfactory reviews, including two 

stores with repeat unsatisfactory reviews, and the findings included employees with little or no 

training, poor knowledge about anti-fraud and AML requirements (including Walmart’s eMSAR 

process), and associates even sharing User or Operator ID numbers and passwords—a tactic 

Walmart’s providers prohibit because it allows unauthorized users to access their money transfer 

systems. 

84. In addition to failing to conduct the required initial and ongoing training for 

employees, in many cases, Walmart also failed to provide prompt mandatory training when 

necessary for its employees. The 2009 Order required, among other things, that MoneyGram 

and its agents take “[p]rompt disciplinary action..., including [by] requiring mandatory fraud 

training” against any location or person authorized to sell money transfer services to prevent 

fraud-induced money transfers. Despite that requirement, in many cases, Walmart has not 

promptly trained its employees when MoneyGram identified particular locations that had high 

levels of fraud and required such training. For example, in some cases, Walmart has failed to 

conduct prompt consumer fraud training and has had locations with outstanding mandatory 

trainings of more than 30, 60, or even 90 days. For the reasons explained above, Walmart’s 

remedial fraud training also has been deficient in many respects. 

85. For many years, the training and resource materials used by Walmart to educate 

its employees about anti-fraud policies and procedures also have been deficient. For example, as 

explained above, while Walmart’s training typically directed employees to refuse to send money 

transfers when they identified red flags indicating a sender may be a victim of fraud, until at least 

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mid to late 2018, that training directed employees only to complete paper MSARs, but not to 

refuse payouts, when they identified red flags indicating a receiver may be a suspected fraudster. 

For many years, Walmart’s resource materials also only focused on preventing fraud when 

employees suspected customers may be the victims of fraud, not the perpetrators. A Walmart 

Quick Reference Guide even directed employees to complete transactions when they identified 

red flags indicating that customers may be receiving funds because they are committing 

consumer fraud. 

86. Even though Walmart has been aware for many years that consumers often use 

fake IDs when receiving fraud-induced money transfers, for years, Walmart has provided 

inadequate training and resource materials to its employees in detecting and preventing the use of 

fake IDs at its locations. 

87. For years, Walmart has failed to provide training to its employees about detecting 

and preventing money transfers that are being used to pay for goods or services offered or sold 

through telemarketing or for charitable contributions solicited through telemarketing, even 

though it has been aware that phone calls are commonly used to defraud consumers and the TSR 

Amendment has prohibited “cash-to-cash” money transfers for outbound and inbound 

telemarketing transactions since June 13, 2016. For example, Ria has provided information to 

Walmart about fraud-induced money transfers involving telemarketing, including that from 

January to September 2018, the source of approximately 83 to 88 percent of fraud-induced 

money transfers through Walmart were schemes perpetrated over the phone, yet Walmart did not 

train its employees to detect and prevent money transfers from being used to pay for 

telemarketing transactions. It was not until in or around March 2019, months after the 2018 

MoneyGram order went into effect, that Walmart, at MoneyGram’s request, began prompting its 

associates at the point of sale to ask senders whether they are “sending money for something a 

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telemarketer sold” to them, and if the answer is “yes,” to cancel and report the transaction. At 

the same time, however, Walmart has failed to train its employees about what constitutes 

telemarketing. Walmart also has not instructed its associates to ask recipients of money transfers 

questions about whether they are being paid for a telemarketing transaction, and if so, to cancel 

those transactions. Since the TSR Amendment went into effect, phone calls have continued to be 

a large source of fraud-induced money transfers at Walmart locations and, in some cases, 

Walmart associates still do not ask senders whether their transfers are related to telemarketing. 

Walmart has Failed to Properly Oversee its Employees Responsible for Providing 

Money Transfer Services 

88. For many years, Walmart has failed to properly supervise the employees at its 

Customer Service Desk and in its MoneyCenters in the provision of money transfer services. As 

an agent, Walmart has control over whether to conduct due diligence and background checks on 

its employees, assign employees authorized to process money transfers with unique User or 

Operator ID numbers and passwords for their individual use, give employees resource materials 

containing information about policies and procedures relating to money transfer services, ensure 

that its employees are complying with all policies and procedures, and monitor the activities 

involving its Customer Service Desks and MoneyCenters to ensure compliance with all antifraud and AML policies and procedures. Indeed, Walmart’s providers require Walmart to 

perform these oversight responsibilities. 

89. Walmart’s oversight of its employees at its Customer Service Desks and in its 

MoneyCenters is especially important because of the large number of employees responsible for 

providing money transfer services and the high volume of money transfers conducted at 

Walmart’s locations. For example, in 2014, Walmart had approximately 2.2 million employees 

worldwide, of which approximately 1.3 million were based in the United States. Walmart has 

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over 4,700 locations in the United States at which money transfer services are provided, and at 

any given time, over 60,000 employees provide money transfer services to consumers. These 

employees are responsible for handling over one billion financial transactions annually, which 

include tens of millions of money transfers sent from Walmart locations each year. In 2016 

alone, Walmart sent approximately 43 million money transfers on behalf of its customers. 

90. From 2017 through 2019, Ria’s compliance reviews of Walmart locations have 

identified that a significant number of Walmart’s stores are high risk for fraud (based on various 

risk factors) or have unsatisfactory reviews. For example, from January through September 

2017, Ria’s reviews of 731 stores revealed that 399 stores were considered “critical high risk,” 

192 stores were considered “high risk,” and 61 stores had unsatisfactory reviews. From January 

through October 2018, Ria’s reviews of 635 stores revealed that 230 stores were “critical high 

risk,” 140 stores were considered “high risk,” and 81 stores had unsatisfactory reviews. From 

January through August 2019, Ria’s reviews of 473 stores revealed that 188 stores were 

considered “critical high risk,” 96 stores were considered “high risk,” and 77 stores had 

unsatisfactory reviews. Overall, from January 2017 through August 2019, approximately 11 

percent of the Walmart stores reviewed by Ria had unsatisfactory ratings. 

91. Walmart is solely responsible for conducting background checks on its employees 

and assigning those associates authorized to process money transfers at its locations with unique 

User or Operator ID numbers. Walmart does not routinely share with its providers the names of 

or information about those employees unless they request that information. Nevertheless, 

Walmart has primarily relied on its providers for identifying corrupt or complicit employees at 

its locations, even though those individuals are employed and supervised by Walmart. 

92. Walmart has failed to ensure that all of its Customer Service Desks and 

MoneyCenters have the required resource materials available to assist its employees in providing 

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money transfer services. For example, even though Walmart requires its Customer Service 

Desks and MoneyCenters to have a Money Service Business Book, also referred to as an MSB 

Binder, and certain job aids, such as a Quick Reference Guide and an AML Infographic 

(“Infographic”), which include information about the procedures Walmart employees must 

follow when processing money transfers, including procedures relating to consumer fraud, 

compliance reviews by Walmart’s providers have revealed that many Walmart locations were 

missing these materials. For example, in 2014, Ria’s reviews of 298 high-risk stores revealed 

that nearly a quarter were missing the Quick Reference Guide. In February 2018, Ria’s reviews 

of 65 stores in five states revealed that 12 percent were missing the Infographic and six percent 

were missing the Quick Reference Guide. More recently, in a July 2019 review conducted by 

Ria of 48 Walmart locations in four states, at least 14 stores were missing the required job aid, 

while an additional eight stores were missing certain materials that were supposed to be 

contained in the MSB Binder. In addition, as described below, for many years, Walmart’s 

providers have found that some Walmart stores did not have the required send forms (with 

consumer fraud warnings), fraud awareness brochures or pamphlets, or consumer fraud warning 

signs. 

93. For many years, both MoneyGram’s and Ria’s compliance reviews of Walmart 

locations have also found that Walmart’s employees have not been complying with the 

providers’ and/or Walmart’s policies and procedures for providing money transfer services. For 

example, in 2015 and 2016, MoneyGram’s compliance reviews of hundreds of Walmart 

locations routinely found that Walmart’s employees had failed to properly complete required 

information for transaction records, report or escalate suspicious activities as required, and verify 

customers’ identities when required. In 2017, MoneyGram informed Walmart that throughout its 

monthly reviews of locations, it had repeatedly found that Walmart’s locations were not properly 

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completing required information in transaction records, and that “[c]apturing incomplete or 

incorrect data directly not only impacts MoneyGram’s capacity to monitor and interdict 

customers efficiently, but it also affects Wal-Mart since it keeps bringing suspicious customers to 

Wal-Mart locations.” For example, during MoneyGram’s monthly call with Walmart on July 6, 

2017, MoneyGram included information about its May reviews of 29 stores and highlighted that 

at least five of those stores had significant data integrity issues for money transfers sent from 

those stores. In fact, no physical address or an incomplete address (with no street name or house 

number) had been recorded for between 9 and 28 percent of all money transfers sent from those 

locations. 

94. In addition, although Walmart’s employees have been required to report 

suspicious activities through MSARs, and then eMSARs beginning in May 2017, they often have 

failed to do so. For example, from July through September 2017, MoneyGram’s reviews of 87 

stores in 14 states revealed that 64 percent of the locations were not knowledgeable about 

eMSARs or were not escalating or referring eMSARs as required. In January 2018, a 

MoneyGram audit of 24 stores in Florida and Texas, which had over 50,000 money transfers sent 

and over 19,000 money transfers received in a three-month period, revealed that: (1) 25 percent 

of the stores were not executing eMSARs—which meant they were not stopping fraud at the 

location; (2) 58 percent of the stores were executing eMSARs, but then not calling MoneyGram 

to ensure that the consumers’ money transfers were stopped; (3) 33 percent of the stores had 

secondary associates who were authorized to provide money transfer services, but were not 

experienced or knowledgeable about how to execute eMSARs; and (4) 16 percent of the stores 

had associates who were identified as needing to be removed from their roles in financial 

services. 

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95. MoneyGram’s reviews in 2018 and 2019 continued to find that Walmart 

associates lacked knowledge about the eMSAR process, as well as other basic and important 

procedures. For example, from April to July 2018, MoneyGram’s reviews of 1,586 associates at 

219 stores in 16 states, the District of Columbia, and Puerto Rico found that between 404 and 

1,019 associates needed training on suspicious activity, fraud examples, eMSAR usage, and ID 

acceptance. From March to May 2019, MoneyGram’s reviews of 155 stores in 16 states and the 

District of Columbia found that hundreds of associates needed training about ID requirements 

and acceptance, and eMSAR usage and knowledge. Moreover, for 2019 overall, MoneyGram’s 

reviews of 476 stores in numerous states found that at least 40 percent of associates needed 

training on potentially suspicious activity, 36 percent of associates needed training about 

eMSAR knowledge, and 18 percent of associates needed training on ID acceptance and 

requirements. 

96. Ria’s reviews of Walmart stores made findings similar to those in MoneyGram’s 

reviews. For example, from January through August 2019, Ria’s reviews of 473 Walmart stores 

in 30 states found that a substantial number of Walmart associates—between 414 and 1,400—

needed training about eMSAR usage and knowledge, fraud, suspicious activity, ID requirements 

and acceptance, structuring (breaking up transactions into smaller dollar amounts) and flipping 

(shortly after receiving funds, sending a large portion to another recipient). 

97. Walmart’s failure to properly supervise and monitor employees at its Customer 

Service Desks and MoneyCenters has also allowed employees to become complicit in the frauds. 

Walmart’s internal records show numerous instances in which employees have been complicit, 

or possibly complicit, in the frauds. These records demonstrate that, for many years, employees 

have, among other things, received cash tips for their assistance in processing fraud-induced 

money transfers, allowed individuals to use multiple names and/or IDs in picking up money 

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transfers, used the same personally identifiable information for different customers, structured 

transfers for customers to avoid ID requirements, made up fictitious information for customers, 

or conducted suspicious money transfers themselves. For example, in 2013, a Customer Service 

Department associate engaged in flipping, where she received money transfers from multiple 

senders in the United States, kept a portion for herself, and sent a portion of the funds to 

receivers in other countries. She also had other associates facilitate her activity by going to 

different coworkers in her department in order to try to avoid detection. In 2014, a MoneyCenter 

associate admitted she had received several hundred dollars on multiple occasions from 

customers using different names and performing fraudulent transactions. In 2015, a different 

MoneyCenter associate, who was the subject of three complaints received by MoneyGram in 

2014, received at least 12 transfers totaling $13,860.35 and sent at least 32 transfers totaling 

$32,059 to Nigeria and Ghana in approximately six and a half months. In 2016 and early 2017, 

at least two associates allowed a manager from another department, who sent or received over 

$35,000 in suspicious transfers in a six-month period, to use the ID information of three other 

associates to complete her transfers. In 2017, a MoneyCenter associate, who sometimes used 

another associate’s Operator ID, processed at least 28 money transfers totaling $22,472.50 over a 

ten-day period when no customer was even present. In another instance, in 2018, an associate 

admitted to keying in fraudulent information for 93 individual transactions. In 2019, an associate 

entered/recorded the same false phone number as the customer’s number for 177 transactions 

involving different customers in a 90-day period, which represented 22 percent of the money 

transfers she processed.

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Walmart has Failed to Adequately Monitor, Investigate, and Mitigate Suspicious Money 

Transfer Activity and Consumer Fraud at its Locations 

98. For many years, Walmart has failed to adequately monitor, investigate, and 

address suspicious money transfer activity to detect and prevent consumer fraud at its locations. 

Instead, Walmart has relied heavily upon its providers to mitigate consumer fraud at its locations 

while failing to take basic and important steps to detect and prevent consumer fraud. 

99. Beginning in April 2014, Walmart became a dual agent when it began offering 

Walmart2Walmart money transfers through Ria at the same locations in the United States where 

it offered money transfer services through MoneyGram. Because MoneyGram and Ria are not 

able to monitor the activity through the other provider’s money transfer system, Walmart is the 

only party with visibility at its locations into the money transfers flowing through both money 

transfer systems. Notwithstanding, Walmart has failed to effectively detect and prevent fraudinduced money transfers through both MoneyGram’s and Ria’s money transfer systems. 

100. In many cases, fraudsters have been able to exploit Walmart’s many 

vulnerabilities to consumer fraud, including those related to: number of shifts, workforce size, 

and high turnover of associates responsible for processing money transfers; heavy customer 

traffic at its MoneyCenters and Customer Service Desks; deficiencies in Walmart’s anti-fraud 

program, including with respect to the training, knowledge, and oversight of its associates 

responsible for providing money transfer services; and Walmart’s dual agency in offering money 

transfers through two money transfer systems. 

101. Walmart has primarily relied on its providers to block certain money transfer 

activity, including money transfers of individuals who have been the subject of complaints, even 

though Walmart has been aware of weaknesses and deficiencies in its providers’ interdiction 

(blocking) systems that make those systems susceptible to use by fraudsters, as well as the 

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inherent risks that come with having more than one provider. For example, Walmart has been 

aware that these interdiction systems can be circumvented by consumers simply by changing 

certain pieces of biographical information, such as names, addresses, or dates of birth, or by 

using fake IDs or switching to another money transfer provider at Walmart. In addition, from 

approximately April 2015 through October 2016, MoneyGram experienced some technical 

problems with its interdiction system, which is used to block consumers, including suspected 

fraudsters, in its network. Walmart did not become aware of MoneyGram’s interdiction system 

difficulties until mid-2016, even though Walmart’s own monitoring of money transfers should 

have alerted it sooner that MoneyGram was not properly blocking suspected fraudsters and 

repeat victims. Because Walmart relied on its providers’ blocking systems, instead of having its 

own, and its practice was not to train its employees to reject payouts of money transfers that were 

suspicious and potentially fraudulent, Walmart’s failures on these fronts made fraud-induced 

money transfers through its stores more likely. 

102. Walmart has had inadequate and ineffective policies and procedures for 

submitting information to its providers and requesting that certain consumers be blocked from 

sending or receiving money transfers due to their suspicious money transfer activity. Walmart 

did not even begin providing Ria with lists of consumers to be blocked in its network until mid to 

late 2016. In addition, for years, when employees faxed MSARs or submitted eMSARs 

regarding potential victims or suspected fraudsters to Walmart’s Home Office, Walmart did not 

promptly submit requests to its providers that those individuals be blocked from using their 

money transfer systems. Walmart also has not provided the third party responsible for preparing 

Walmart’s blocking requests with the resources, such as the consumer fraud reports and 

transaction data provided by Walmart’s providers, to enable them to identify customers who 

should be blocked. In addition, for many years, when it identified customers with suspicious 

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activity in one of its provider’s systems, it only sent blocking requests to that provider, even 

though the customers could use the other money transfer system available at Walmart locations. 

Up until late 2018, Walmart also did not have any mechanism in place to ensure that when 

associates at its Customer Service Desks and in its MoneyCenters rejected a transfer at the point 

of sale, that information was promptly transmitted to Walmart’s providers to prevent customers 

from going to another employee or location to send or receive their transfers. 

103. Walmart also failed to adequately monitor suspicious money transfer activity at 

its locations, such as consumers receiving money transfers at multiple different Walmart 

locations in the same geographic area or visiting Walmart locations in different states. Instead, 

for many years, Walmart has primarily relied on its providers for addressing those suspicious 

activities, including for purposes of restricting or suspending Walmart locations, while failing to 

adequately address consumer fraud at its locations. In many cases, Walmart has not prevented 

consumers, including its own employees, from sending or receiving highly suspicious money 

transfers that it knew or had reason to believe were related to consumer frauds. In other cases, 

Walmart has continued to process fraud-induced money transfers while turning a blind eye to 

suspicious characteristics or other indicators that the transfers were induced by fraud. For years, 

Walmart has frequently processed transactions that had suspicious characteristics, including: 

(1) high-dollar money transfers; (2) patterned activity, such as multiple transfers involving 

similar dollar amounts; (3) one-to-many or many-to-one transactional activity; (4) highfrequency money transfers; (5) transactions with data integrity issues (issues relating to ID 

numbers, addresses, dates of birth, or other information about recipients); (6) same IDs or 

addresses used by multiple receivers; (7) money transfers picked up using fake out-of-state IDs; 

(8) flipping; (9) structuring of transactions; (10) back-to-back transfers; (11) substantial transfers 

to high-risk countries known for fraud; (12) transactions where the sender and receiver do not 

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appear to have a relationship; and (13) transactions with indications of elder financial 

exploitation due to the senders’ age. 

104. Based on information contained in MoneyGram’s complaint database, fraudinduced money transfers at Walmart often have involved high-dollar amounts and have been 

picked up using out-of-state, including foreign, IDs. From 2013 to 2018, money transfers of 

$900 or more accounted for over 47 percent of the total number of complaints involving 

Walmart. Of the reported fraud transfers paid out at Walmart where the receiver’s ID 

information was recorded, a majority (over 53 percent) of the transfers of $900 or more were 

picked up using an out-of-state ID. 

105. Between January 2015 and February 2019, at least 101 Walmart locations have 

been responsible for paying out over $100,000 in fraud-induced money transfers that were the 

subjects of complaints, including at least 11 locations that paid out over $200,000 in transfers 

that were the subject of complaints. These locations include the following: 

a. Walmart location #3159 in Teterboro, New Jersey paid out at least 150 

reported fraud-induced money transfers totaling $272,945.50. Of the 101 

Walmart locations responsible for paying out over $100,000 in reported fraudinduced transfers, this location had the highest average reported fraud amount at 

$1,819.64. This location paid out 63 reported fraud-induced transfers totaling 

$111,480.79 through MoneyGram and 87 reported fraud-induced transfers 

totaling $161,464.71 through Ria. A majority of the total complaints (72.6 

percent) involved the grandparent or emergency scam. From May 9, 2017 until 

July 27, 2017, the location paid out 34 reported fraud-induced transfers through 

MoneyGram totaling $73,923.17, of which 88.2 percent (or 30 of the 34 transfers) 

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year period, from September 24, 2016 to September 24, 2018, 93 percent of the 

Ria reported fraud-induced transfers paid out by the location involved a phone 

call to the victim, and 85 percent involved the grandparent or emergency scam. 

MoneyGram and Ria have restricted receives at this location at least three times, 

including two restrictions by MoneyGram, from July to December 2017 and April 

to July 2018, and a more recent restriction by Ria, from October 2019 to January 

2020. 

b. Walmart location #5293 in Valley Stream, New York paid out at least 358 

reported fraud-induced money transfers totaling $424,213.81. This location had 

the highest reported fraud by amount in the Walmart chain, of which, 141 fraudinduced transfers totaling $198,389.11 involved MoneyGram, and 217 fraudinduced transfers totaling $225,824.70 involved Ria. In 2017 alone, the location 

paid out 156 complaints totaling $197,455.80, of which 113 complaints totaling 

$136,546.68 were through Ria’s system. MoneyGram and Ria have restricted 

receives at this location at least four times, including a restriction by MoneyGram, 

from November 2018 to August 2019, and three restrictions by Ria, from January 

to March 2018, from August 2019 to January 2020, and more recently, in 

February 2020. 

c. Walmart location #4383 in Dearborn, Michigan paid out at least 799 

reported fraud-induced money transfers totaling $277,601.06, which was the 

largest volume of complaints in the Walmart chain. The location has paid out at 

least 322 fraud-induced transfers totaling $111,861.72 through MoneyGram and 

477 fraud-induced transfers totaling $165,739.34 with Ria. Together, 

MoneyGram and Ria have disciplined this location at least nine times. 

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MoneyGram has disciplined this location at least five times, including two 

restrictions on receives that were imposed in October 2015 and January 2017, and 

three suspensions, including two short suspensions in December 2017 and 

December 2018, and a thirteen-month suspension that began in January 2019. Ria 

has disciplined this agent at least four times, including at least three suspensions 

on receives, consisting of a four-month suspension in November 2017, a weekand-a-half suspension in December 2018, and a thirteen-month suspension 

beginning in January 2019, as well as at least one restriction on receives for a 

two-month period beginning in March 2018. 

d. Walmart location #5129 in Landover Hills, Maryland has paid out at least 

368 reported fraud-induced money transfers totaling $233,897.28, of which 162 

reported fraud-induced transfers totaling $123,134.28 went through MoneyGram 

and 206 reported fraud-induced transfers totaling $110,763 involved Ria. 

MoneyGram and Ria have taken disciplinary actions against this location at least 

six times. MoneyGram restricted receives at this location at least twice, in 

November 2015 and October 2016, and imposed a ten-day suspension in January 

2019. Ria restricted receives at this location at least twice, from February to April 

2018 and July to December 2019, and suspended receives at this location at least 

once, from January to February 2019.

Walmart has Failed to Adequately Warn Consumers about Fraud-Induced Money Transfers

106. Despite its awareness of a significant amount of consumer fraud involving 

Walmart locations, for many years, Walmart has failed to properly warn consumers about fraudinduced money transfers, including by ensuring that its locations consistently had visible 

warning signs and brochures or pamphlets about consumer fraud, asking consumers whether 

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their money transfers were related to telemarketing, and warning consumers that “cash-to-cash” 

money transfers for outbound and inbound telemarketing transactions were prohibited under the 

TSR since June 2016. In addition, although for years Walmart’s providers provided some 

general warnings on the first page of send forms located at some of its agent locations, in many 

cases, Walmart locations did not even have send forms. Therefore, consumers often have been 

unaware of the risks associated with sending money through the money transfer system.

107. Despite advance notice of reviews by Walmart’s providers, the reviews routinely 

revealed that some of Walmart’s locations were missing send forms and consumer fraud signs, 

brochures or pamphlets, and other warnings. For example, in January 2018, Ria’s reviews of 62 

stores in four states revealed that 24 percent did not have send forms, 23 percent did not have 

consumer fraud warning signs, and 15 percent did not have fraud awareness brochures. In 

February 2018, Ria’s reviews of 65 stores in five states revealed that 31 percent did not have 

send forms, 17 percent did not have consumer fraud warning signs, and 23 percent did not have 

fraud awareness brochures. From January through August 2019, Ria conducted 473 reviews of 

Walmart stores in 30 states and found that 114 stores (24 percent) of those stores did not have 

send forms and 186 stores (39 percent) of them were missing fraud awareness materials.

108. Like Ria, MoneyGram also routinely found that some of Walmart’s stores were 

missing required materials relating to consumer fraud warnings. For example, in MoneyGram’s 

April 2018 reviews of 47 stores in five states, MoneyGram found that four stores (nine percent) 

were missing send forms, five stores (11 percent) were missing fraud signs, and nine stores (19 

percent) were missing fraud pamphlets. From April to July 2018, MoneyGram’s reviews of 219 

stores in 16 states, the District of Columbia, and Puerto Rico found that 18 stores (eight percent) 

were missing the consumer complaint notice, 21 stores (ten percent) were missing send forms, 29 

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stores (13 percent) were missing fraud signs, and 32 stores (15 percent) stores were missing 

fraud pamphlets.

Walmart has Failed to Report All Consumer Fraud Involving its Locations 

109. For many years, although Walmart has primarily relied on its providers to address 

and mitigate consumer fraud involving its locations, Walmart has failed to provide information 

to them about all of the complaints and reports it has received about fraud-induced money 

transfers involving its locations. For example, despite receiving complaints and reports that 

some of Walmart’s own employees have been involved in sending or receiving thousands, or 

even tens of thousands, of dollars in suspicious money transfers at its locations, Walmart has not 

routinely provided that information to its providers—even in cases when it has determined that 

those employees have been the victims of, or participants in, fraud-induced money transfers. 

110. Walmart’s providers record information about fraud-induced money transfers in 

their complaint databases, which they use to administer their anti-fraud programs. For example, 

Walmart’s providers have used that information to: (a) monitor and identify agent locations and 

employees that have not been taking adequate steps to address consumer fraud, or may even be 

complicit in frauds; (b) create automated rules regarding particular corridors (e.g., limiting the 

number and amount of money transfers to receivers); (c) interdict individuals who are the victims 

or the perpetrators of frauds; and (d) take corrective actions against locations with elevated levels 

of fraud. Therefore, Walmart’s failure to report all fraud-induced money transfers it becomes 

aware of has impeded its providers’ efforts to mitigate consumer fraud involving Walmart. 

Walmart has Failed to Take Other Reasonable Measures to Mitigate Fraud 

in Connection with its Processing of Money Transfers 

111. For many years, Walmart has failed to take other reasonable measures to mitigate 

consumer fraud in connection with providing money transfer services, such as taking more 

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effective measures to properly verify and validate the legitimacy of consumers’ IDs, limiting the 

associates responsible for providing money transfer services to only those with proper training 

and knowledge about how to detect and prevent fraud-induced money transfers, providing its 

associates with a point-of-sale system that allows them to more effectively address suspicious 

activities by consumers, and imposing a limit on the amount of money that can be paid out in 

cash, as opposed to other more traceable forms of payments, to recipients of money transfers. 

THE TSR’S CASH-TO-CASH MONEY TRANSFER BAN

112. In June 2016, the Commission amended the TSR to ban the use of cash-to-cash 

money transfers in telemarketing transactions. Specifically, the amendment prohibits the use of 

cash-to-cash money transfers as payment for goods or services offered or sold through 

telemarketing, or charitable contributions solicited or sought through telemarketing. 16 C.F.R. 

§ 310.4(a)(10). This provision applies to all telemarketing transactions that involve a payment 

for goods or services, or the solicitation of a charitable contribution, not just transactions where 

the payment was induced by fraud. 

113. The Commission addressed the reasons for this bright-line rule in the TSR’s 2015 

Statement of Basis and Purpose (“SBP”), explaining that cash-to-cash money transfers “are used 

almost exclusively by perpetrators of telemarketing fraud,” who “typically ignore” the TSR’s 

requirements. 80 Fed. Reg. at 77,524. These perpetrators “frequently instruct consumers to use 

cash-to-cash money transfers because this method of payment is a fast way to extract money 

anonymously and irrevocably from the victims of fraud.” Id. at 77,543. Legitimate 

telemarketers, the Commission explained, “simply do not rely on ... cash-to-cash money 

transfers to receive payment for goods or services purchased over the telephone.” Id. at 77,551. 

114. The Commission noted that cash-to-cash money transfers are a “novel payment 

method” when used in telemarketing transactions because such transfers lack the “security” of 

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conventional payment methods, such as credit cards and electronic fund transfers, which are 

“processed or cleared electronically through networks that can be monitored systematically for 

fraud.” Id. at 77,521. Money transfers also “lack the same error resolution rights and liability 

limits” as conventional payment methods and “expose consumers to the risk of unrecoverable 

losses from telemarketing fraud.” Id. at 77,524. 

115. As a business that processes cash-to-cash money transfers, Walmart must comply 

with the TSR’s prohibition on such transfers in covered telemarketing transactions. The 

Commission specifically declined to provide money transfer businesses like Walmart a safe 

harbor from the cash-to-cash money transfer ban. Id. at 77,552. 

116. Indeed, the Commission’s 2015 SBP made clear that money transfer businesses 

play an important role in educating people about the ban and sharing the ban’s “bright line 

guidance” with their customers. Id. at 77,551-52. For example, the Commission specifically 

contemplated that money transfer businesses could attempt to comply with the ban by asking 

consumers questions about the transaction for the purpose of identifying the types of transfers 

prohibited by the ban, including whether the transfer involved telemarketing and questions about 

the consumer’s relationship with the receiver and reasons for sending the money. Id. at 77,551 

& n.394. The Commission also explained that the TSR ban on cash-to-cash money transfers 

would enable money transfer businesses like Walmart to provide a clear and concise warning to 

their customers that: “It is illegal for telemarketers [to] ask consumers to wire cash.” Id. at 

77,551. 

117. The measures described in the Commission’s 2015 SBP for complying with the 

cash-to-cash ban were later incorporated into the Western Union order that Walmart received in 

January 2017. For example, that order requires Western Union and its agents to ask 

consumers—before completing their money transfers—whether their transfers are to pay for 

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goods or services offered or sold through telemarketing and if so, to decline to process such 

transfers. The order also requires Western Union and its agents to warn consumers that money 

transfer payments for goods or services sold through telemarketing are illegal. 

118. After the June 2016 amendments took effect, Walmart did nothing to attempt to 

comply with the cash-to-cash money transfer ban. Walmart did not implement any of the 

measures identified in the 2015 SBP or the Western Union order, or any other measures, to avoid 

processing money transfers prohibited by the ban. Indeed, Walmart continued instructing its 

employees to complete even suspicious transactions, which would include payouts to 

telemarketers and their associates that were prohibited by the cash-to-cash ban. 

119. For years, Walmart processed cash-to-cash money transfers that violated the 

TSR’s cash-to-cash ban. It did nothing whatsoever to attempt to comply with that ban until at 

least March 2019. 

120. Even today, in some instances, Walmart employees still do not ask questions to 

attempt to determine whether a consumer’s money transfer is a payment for goods or services 

offered or sold through telemarketing or for a charitable contribution solicited or sought through 

telemarketing. In many instances, moreover, Walmart employees also do not provide consumers 

with a clear, concise, and conspicuous warning that it is illegal for any seller or telemarketer to 

accept a cash-to-cash money transfer as payment for goods or services offered or sold through 

telemarketing or payment for a charitable contribution solicited or sought through telemarketing. 

121. By continuing to process money transfers without taking any steps to attempt to 

identify those transfers that would be prohibited by the cash-to-cash ban, Walmart has provided 

substantial assistance or support to sellers or telemarketers while consciously avoiding knowing 

that they are violating the TSR’s cash-to-cash ban. 

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WALMART’S SUBSTANTIAL ASSISTANCE OF TELEMARKETING SCHEMES 

THAT VIOLATE THE TSR 

122. For many years before the cash-to-cash ban went into effect—and continuing to 

the present—Walmart has processed large numbers of money transfers exhibiting the highly 

suspicious and easily identifiable characteristics of telemarketing schemes that violate one or 

more provisions of the TSR, including the TSR’s cash-to-cash ban. 

123. These schemes have involved telemarketers or sellers located around the world 

who initiate or receive telephone calls to or from a customer or donor in connection with a plan, 

program, or campaign to induce the purchase of goods or services, or to solicit charitable 

contributions, through the use of one or more telephones and which involve more than one 

interstate telephone call. 

124. The telemarketers and sellers engaged in the schemes described in the previous 

paragraph that utilize Walmart’s money transfer services to obtain payment from their victims 

have (1) made false or misleading statements to induce people to pay for goods, services, or 

charitable contributions, and (2) requested or received advance fees for a loan or other extension 

of credit while guaranteeing or representing a high likelihood of success in obtaining a loan or 

extension of credit. 

125. As detailed below, some of the typical telemarketing schemes for which Walmart 

locations have processed money transfer payments have included lottery, prize, and sweepstakes 

scams, advance-fee loan scams, government imposter and utility scams, and person-in-need, 

grandparent, and emergency scams. All of these telemarketing schemes typically involve 

telemarketers or sellers who initiate or receive telephone calls to or from a customer in 

connection with a plan, program, or campaign to induce the purchase of goods or services, or to 

solicit charitable contributions, through the use of one or more telephones and which involve 

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more than one interstate telephone call. For many years, MoneyGram and Ria have shared 

complaints with Walmart about money transfers sent and/or received at its stores, including 

information about the senders, receivers, and the type of scam involved. In addition, Ria has 

provided information, such as statistics, to Walmart about fraud-induced money transfers that 

were perpetrated over the telephone. 

126. Walmart has failed to detect and prevent telemarketing-related money transfers—

on both the send and receive sides of the transactions—that have exhibited characteristics that 

should have led Walmart to suspect fraud. The amount of a typical money transfer ranges from 

approximately $250 to $400, and the typical transfer is usually sent to the same family members 

or friends once or twice a month. By contrast, as described below, telemarketing-related 

transfers, including fraud-induced transfers, stand out from typical legitimate transfers in various 

ways that should be noticeable to Walmart. For example, those transfers often involve dollar 

amounts that are higher than the typical transfer. They also often involve multiple money 

transfers sent or received in relatively short periods of time, back-to-back transfers, flipping, 

transfers to high-risk countries known for fraud (such as Nigeria or Jamaica), recipients using 

fake IDs or out-of-state IDs in picking up the transfer, transfers between senders and receivers 

with no apparent relationship, the use of name or address variations, and/or switching between 

the MoneyGram, Western Union, and Ria money transfer systems. 

127. Significantly, moreover, many victims of telemarketing schemes for which 

Walmart has processed money transfers have not sent a money transfer previously. Walmart has 

the ability to identify first-time users because its point-of-sale system automatically populates 

information for repeat customers, but not those sending money transfers for the first time from its 

locations. Many first-time senders of money transfers at Walmart locations have sent transfers 

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with one or more of the suspicious characteristics outlined above without being identified or 

stopped by Walmart employees. 

128. Elderly consumers who have been targeted by telemarketing scams often use 

Walmart locations to send the requested money transfer. Many of these elderly victims also are 

first-time users of Walmart’s money transfer services. Walmart’s own training reflects that the 

company knows that elderly consumers are often targeted and that they frequently send the 

requested transfers from Walmart locations, but as described in the examples below, Walmart 

has frequently not asked these consumers questions about their transfers or provided them with 

clear and conspicuous warnings—even when their transactions have exhibited suspicious 

characteristics. 

129. For years, Walmart has allowed telemarketers engaged in schemes involving a 

plan, program, or campaign to offer or sell goods or services via one or more interstate telephone 

calls under the TSR to easily obtain payments from their victims. In many instances, Walmart 

has not taken basic steps to protect consumers from telemarketing schemes, even when such 

steps have been required by its money transfer service providers and/or the FTC’s prior 

MoneyGram and Western Union orders, including by: (1) failing to ask senders questions about 

whether their transfers are related to telemarketing; (2) failing to provide clear, concise, and 

conspicuous warnings that it is illegal for any seller or telemarketer to accept payments through a 

money transfer for goods or services offered through telemarketing; (3) failing to provide other 

warnings about common scams, which often involve telemarketing; and (4) failing to adequately 

address transfers exhibiting red flags, including by not properly training employees about how to 

respond to those types of transfers. 

130. Properly trained frontline employees at Walmart should be able to regularly 

identify and stop many of these suspicious transfers simply by following basic procedures, 

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including by asking questions and providing clear and conspicuous warnings to senders and 

receivers. In addition, Walmart’s own monitoring and oversight of money transfer activity at its 

locations should also identify and stop suspicious transfers. These responsibilities are especially 

important because Walmart is the only party with visibility into the money transfer activity 

flowing through the multiple money transfer providers, including MoneyGram, Western Union, 

and Ria, whose services are available at Walmart locations. 

131. In some instances, Walmart has known or consciously avoided knowing that its 

own employees were complicit or potentially complicit in facilitating payments for telemarketing 

schemes. For example, between approximately November 20 and November 29, 2017, a 

complicit Walmart associate in Beaumont, Texas cashed out at least 28 money transfers totaling 

$22,472.50—when no customer was present in furtherance of a telemarketing scheme involving 

a secret shopper employment scam. This secret shopper scheme involved a plan, program, or 

campaign to induce the purchase of goods or services through the use of one or more telephones 

and more than one interstate telephone call. The Walmart associate who assisted the scheme 

later admitted—in January 2018—that she understood the transfers to be fraudulent and that she 

provided the money to a man, who she believed was from Nigeria. One of the victims of the 

secret shopper scheme responded to an exclusive job opportunity for college students and had 

more than one interstate telephone call with a telemarketer in which he was directed to cash a 

check—which later proved to be fake—and then send a majority of the funds from a Walmart 

location to evaluate Walmart’s money transfer services. He was told to keep the remaining funds 

as compensation for acting as a secret shopper and evaluating the location’s employees and 

money transfer services. Ultimately, the consumer sent two transfers through MoneyGram and 

Ria totaling over $1,700 that were cashed out by the corrupt Walmart associate in Texas. 

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132. In another example, between September 2018 and October 2018, a Las Vegas, 

Nevada Walmart location had potentially complicit employees who assisted a telemarketing 

scam by processing multiple back-to-back money transfers for an individual who consistently 

used different addresses, telephone numbers and out-of-state IDs. Specifically, on September 11, 

2018, a Walmart associate paid out four transfers to the same individual within a 24-minute 

period, inputting two different addresses and telephone numbers for the receiver, but recording 

the same ID number for all four transactions. The next day, the same associate processed two 

additional money transfers back-to-back for the same individual, and recorded a different 

address, telephone number, and out-of-state driver’s license. Similarly, two other associates at 

the same location paid out back-to-back transfers to the same individual—just minutes apart—in 

September and October 2018, using slight name variations and recording an out-of-state driver’s 

license, slight address variations or incomplete information, and different telephone numbers. At 

least two of the transfers paid out by those associates were later reported to MoneyGram as being 

part of a housing rental scam. As part of a telemarketing plan, program, or campaign to induce 

the purchase of goods or services, one victim had more than one interstate call related to a 

property supposedly for rent. This victim lost $1,581 by paying for a non-existent rental 

property through a money transfer that was paid out at that Nevada Walmart location. On 

October 29, 2018, MoneyGram restricted the amount that could be paid out at that Walmart 

location to $399 after it reviewed transactions that occurred in a recent 45-day window and 

determined that the average dollar amount of transactions at that location that were confirmed as 

fraud-induced, or linked to such transactions, was $953, which is much higher than a typical 

money transfer. 

133. Given the red flags and suspicious characteristics of telemarketing-related 

transfers—on the send and/or receive side of those transfers—and the deficiencies in Walmart’s 

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own anti-fraud program, in numerous instances, Walmart has known or consciously avoided 

knowing about money transfers that enable telemarketers and sellers to collect the proceeds of 

telemarketing schemes that violate the TSR. This is true both before and after the TSR banned 

cash-to-cash money transfers in 2016. In some cases, Walmart has turned a blind eye to this 

illegal activity by failing to ask questions or provide warnings, or by not properly overseeing its 

employees and the money transfer activity at its locations. Moreover, for years, even if 

Walmart’s employees have spotted red flags, Walmart’s policy or practice was to pay out 

transfers even if its employees suspected fraud. As a result, Walmart has assisted the 

telemarketers and sellers in collecting the proceeds of their illegal activities. 

Lottery, Prize, and Sweepstakes Scams 

134. One telemarketing scam for which Walmart has regularly processed payments 

that it knew or consciously avoiding knowing violated the TSR is a lottery, prize or sweepstakes 

scam. In this scam, telemarketers, who are often located outside the United States, call 

consumers throughout the United States or mail them a piece of direct mail with a telephone 

number for consumers to call. During the calls, telemarketers tell consumers—who are often 

elderly—that they have won a lottery, prize, or sweepstakes, but that in order to collect their 

winnings, they must first pay through a money transfer a fee for taxes or insurance on their 

winnings, or some other type of processing or shipping and handling fee. These transfers 

frequently exhibit one of more of the red flags outlined above, including the involvement of 

elderly and/or first-time senders of a money transfer, high-dollar amounts (individually or in 

aggregate), and multiple money transfers in relatively short periods of time. In many instances, 

moreover, consumers must send the money transfer to collect their winnings outside the United 

States to countries like Jamaica, which Walmart knows is often the location of these types of 

scams and the destination for these transfers. In other instances, the transfer is sent to a money 

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mule in the United States, who then flips at least a portion of the money through another transfer 

to a country outside the United States. Such “flipping” to a country outside the United States is 

an obvious red flag of fraud. After consumers pay the required fee by sending a money transfer 

at a Walmart location, they never receive the promised winnings. 

135. Between January 1, 2013 and December 31, 2018, MoneyGram and Ria received 

a total of at least 13,190 complaints reporting losses of $8,404,539 (including fees) about lottery, 

prize, or sweepstakes scams where the proceeds were sent from or picked up at a Walmart 

location. Between January 1, 2013 and December 31, 2018, MoneyGram received at least 8,375 

complaints with losses of $5,879,474 about lottery scams, and between April 24, 2014 and 

December 31, 2018, Ria received at least 4,815 complaints with losses of $2,525,065 about prize 

and lottery scams. Since December 31, 2018, Walmart continues to be the subject of complaints 

about lottery, prize, and sweepstakes scams where the proceeds were sent from or picked up at a 

Walmart location. 

136. Lottery, prize, and sweepstakes scams typically involve a plan, program, or 

campaign to induce the purchase of goods or services using one or more telephones and more 

than one interstate telephone call. For example, from approximately October 2016 until about 

July 2018, two coconspirators, Troy Smith and Michelle Greenwood, the defendants in U.S. v. 

Smith, No. 21-cr-0372 (M.D. Pa.), participated in a plan, program, or campaign involving 

multiple Jamaica-based telemarketers who contacted consumers in the United States by one or 

more interstate telephone calls and induced them to send money transfers to pay for goods or 

services related to a sweepstakes prize they supposedly had won. In furtherance of the scheme, 

Smith and Greenwood regularly visited Walmart locations in the Gulfport-Biloxi, Mississippi 

metropolitan area in order to receive MoneyGram and Walmart2Walmart money transfers sent 

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by victims who were told they had won a sweepstakes prize. Indeed, Smith frequently was able 

to pick up multiple money transfers in the same day from just one of those Walmart locations. 

137. From August 2016 to July 2018, Smith or Greenwood picked up at Walmart 

locations at least 128 money transfers totaling over $134,800 from 24 different individuals in the 

United States, including 58 MoneyGram transfers, oftentimes using different spelling variations 

of their names, but with the same driver’s license numbers. One of them also often used an outof-state driver’s license to pick up the transfers at Walmart locations. Nearly all of those 

transfers were picked up by Smith and Greenwood at Walmart locations in the greater Biloxi, 

Mississippi area, including 82 transfers at just one location between August 2016 and July 2018. 

Many of those money transfers had been sent by elderly consumers located throughout the 

United States. Smith and Greenwood were able to continue picking up transfers from multiple 

senders, including until at least July 2018, even though four elderly consumers had submitted 

complaints to MoneyGram over a four-week period beginning in April 2017 about losing money 

to a lottery scam where Smith had picked up their money transfers. MoneyGram provided these 

complaints to Walmart in May 2017. Despite Walmart having received multiple complaints 

relating to this scam and the multiple red flags the transfers exhibited, Walmart continued to 

allow Smith and Greenwood to pick up scam proceeds at Walmart locations in the greater Biloxi, 

Mississippi area for an additional fourteen months. Even if Walmart’s employees had spotted 

these red flags, however, for years Walmart’s policy or practice was to pay out transfers even if 

its employees suspected fraud. 

138. From at least July 2017 until at least July 2018, Smith also sent at least 130 

money transfers totaling $76,360, including suspicious high-dollar money transfers, from 

Walmart stores to more than three dozen different individuals in Jamaica. Walmart has long 

known and should have trained its employees that Jamaica is a high-risk country due to the 

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proliferation of sweepstakes and lottery schemes operating there. Smith’s money transfer 

activity at Walmart locations—on both the send side to Jamaica and the receive side at stores in 

the greater Biloxi, Mississippi area—was extraordinarily high. By continuing to process 

transactions for this scheme, which had many suspicious characteristics, Walmart knew or 

consciously avoided knowing that it was facilitating TSR violations. 

139. The money transfers sent by victims of the Jamaica-based telemarketing scheme 

involving Smith and Greenwood also had other suspicious characteristics about which Walmart 

knew or consciously avoided knowing. For example, from approximately October 2016 to June 

2017, one victim of the scheme, who received numerous telephone calls over many months 

related to this scam, sent approximately 72 money transfers totaling more than $108,400 through 

MoneyGram and Ria from one Walmart location in Pennsylvania, including twelve transfers 

totaling over $47,845 in a single month, with an average transaction amount of $3,987. The 

victim also sent three transfers from the same Walmart location totaling at least $9,887 in a 

single day in February 2017. This was highly suspicious activity that should have been spotted 

and stopped by Walmart, but it was not. 

140. Another victim of the same Jamaica-based scheme received numerous telephone 

calls in Indiana related to the scheme from approximately June through September 2018. During 

those calls, as part of the plan, program, or campaign, he was told that he had won a prize of $1.5 

million and a Mercedes automobile. He lost at least $5,864.18 by sending thirteen 

Walmart2Walmart money transfers to defendant Smith in Mississippi, and one additional 

transfer to another individual in Indiana. The victim sent twelve of his thirteen money transfers 

from the same Walmart location in Indiana, including sometimes sending multiple high-dollar 

transfers from that single Walmart location on the same day. In sending multiple cash-to-cash 

money transfers from the Walmart location in Indiana, this victim was not asked by any Walmart 

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employee whether his transfers were related to telemarketing, nor was he warned that using 

money transfers to pay for goods or services offered or sold through telemarketing is illegal. In 

addition, when the victim mentioned to Walmart employees that he was sending the money 

transfers to obtain a prize, Walmart employees did not warn him about prize scams or attempt to 

stop him from sending transfers that exhibited multiple characteristics of a scam. As a result of 

Walmart’s failure to stop these transfers, the victim lost nearly $6,000, and he never received 

either of the promised prizes. 

141. These are just some examples of the thousands of U.S. consumers who lost 

money through money transfers that were sent from or received at Walmart locations in the 

United States and that Walmart knew or consciously avoided knowing were related to lottery, 

prize or sweepstakes telemarketing schemes. 

Advance-Fee Loan Scams 

142. A second type of telemarketing scheme for which Walmart has regularly 

processed payments that it knew or consciously avoiding knowing violated the TSR is an 

advance-fee loan scam. In a typical advance-fee loan scam, telemarketers who are often outside 

the United States call consumers located throughout the United States, send them a piece of 

direct mail, or place an advertisement in the general media containing a telephone number to 

call. Consumers who receive calls or respond by phone to direct mail or general advertisements 

are guaranteed that they will receive cash loans or lines of credit, regardless of their credit scores. 

But in order to receive the loan or line of credit, they must first pay via money transfer an upfront 

fee that is claimed to be for “processing,” “insurance,” the “application,” or something else. 

These transfers frequently exhibit one of more of the red flags outlined above, including the 

involvement of elderly and/or first-time senders of a money transfer, high-dollar amounts 

(individually or in aggregate), and multiple money transfers in relatively short periods of time. 

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In many instances, moreover, consumers must send the money transfer required to receive the 

cash loan or line of credit outside the United States, to a country like Canada. In other instances, 

the transfer is sent to a money mule in the United States, who quickly flips the transfer to a 

country outside the United States. Consumers who pay the upfront fee never receive the 

promised loans or lines of credit. 

143. Between January 1, 2013 and December 31, 2018, MoneyGram and Ria received 

a total of at least 16,325 complaints reporting losses of $8,373,856 (including fees) about 

advance-fee loan scams where the proceeds were sent from or picked up at a Walmart location. 

Between January 1, 2013 and December 31, 2018, MoneyGram received at least 15,401 

complaints with losses of $7,749,949 about advance-fee, loan-grant, or other loan scams; and 

between April 24, 2014 and December 31, 2018, Ria received at least at least 924 complaints 

with losses of $623,907 about advance-fee loan scams. Since December 31, 2018, Walmart 

continues to be the subject of complaints about advance-fee loan scams where the proceeds were 

sent from or picked up at a Walmart location. 

144. Advance-fee loan scams typically involve a plan, program, or campaign to induce 

the purchase of goods or services using one or more telephones and more than one interstate 

telephone call. For example, Pradipsinh Dharmendrasinh Parmar, one of the defendants in U.S. 

v. Parmar, No. 19-cr-0160 (E.D. Va.), participated at various times in an advance-fee loan 

scheme that occurred from at least March 2017 until April 2019 and that involved multiple 

money transfers at Walmart locations. Parmar and his coconspirators operated the telemarketing 

scheme through foreign call centers that were located primarily in India and that were owned by 

codefendant Shehzadkhan Khandadkhan Pathan. The scheme targeted victims—particularly the 

elderly—with robocalls and live telemarketing calls, telling consumers over the telephone that 

they had been approved for a loan, but that in order to receive the loan, they needed to make an 

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advance payment as earnest money or an initial installment payment on the loan. The 

telemarketing script used by the scheme specifically directed the victims to send money 

transfers, including Walmart2Walmart transfers, ranging from several hundred to three thousand 

dollars to secure the promised loans. Despite making the required advance payments, consumers 

never received the promised loans. Parmar and Pathan both pleaded guilty to their roles in this 

telemarketing scheme that often used Walmart locations to obtain high-dollar money transfers 

using fake IDs from the scheme’s victims. Moreover, even if Walmart’s employees had spotted 

these red flags, for years Walmart’s policy or practice was to pay out transfers even if its 

employees suspected fraud. 

145. In January 2022, as part of another plan, program, or campaign to offer or sell 

purported advance-fee loans, an elderly consumer from South Carolina received multiple 

telephone calls over the course of a four-day period from a woman who identified herself as 

being with Harborview Lenders in Seattle, Washington. The telemarketer represented that the 

consumer would receive a $5,000 loan but would need to pay an upfront fee of $487.50 because 

of the consumer’s credit rating and as collateral for the loan. The telemarketer also promised 

that the upfront payment would be applied to the loan. The telemarketer directed the consumer 

to go to the nearest Walmart location to pay the required fee through a money transfer. When 

the consumer did so, it took three attempts at the same Walmart location by the same Walmart 

employee to send a money transfer. The first two attempted transfers to two different recipients 

in Canada were blocked by MoneyGram, which should have been a red flag to Walmart, but the 

Walmart employee then allowed the consumer to send the transfer again—this time to a third 

recipient through Western Union instead of MoneyGram. The third transfer was successful. 

Each time, the Walmart employee did not ask the consumer any questions about her transfer or 

provide her with any warnings, as required by the 2018 MoneyGram order. When the consumer 

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did not receive the loan as promised but was instead asked to send more money in a subsequent 

phone call, the consumer realized on her own that she had been scammed. 

146. These are just some examples of the thousands of U.S. consumers who lost 

money through money transfers that were sent from or received at Walmart locations in the 

United States and that Walmart knew or consciously avoided knowing were related to advancefee loan telemarketing schemes. 

Government Imposter and Utility Scams 

147. Impersonation scams were the top fraud reported to the FTC in 2022. IRS scams 

and utility scams are two common types of impersonation scams that are covered by the TSR for 

which Walmart has regularly processed payments that it knew or consciously avoiding knowing 

violated the TSR. In a typical IRS impersonation scam, a telemarketer calls consumers in the 

United States and impersonates an IRS agent, telling consumers they owe money to the IRS for 

back taxes. The telemarketer typically threatens that the back taxes must be paid immediately 

using a money transfer or the consumer will be arrested. In a typical utility impersonation scam, 

the consumer receives a call from a telemarketer claiming to be with their gas, water, or electric 

company, telling them their service will be cut off immediately unless they make a past-due 

payment using a money transfer. In both types of schemes, the caller attempts to create a false 

sense of urgency to scare people into making payments. These transfers frequently exhibit one 

of more of the red flags outlined above, including the involvement of elderly and/or first-time 

senders of a money transfer, high-dollar amounts (individually or in aggregate), and multiple 

money transfers in relatively short periods of time. In many instances, moreover, consumers are 

asked to send the money transfer outside the United States to countries known for fraud. In other 

instances, the transfer is sent to a money mule in the United States, who quickly flips the transfer 

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to a country outside the United States. After consumers send the money transfer, they learn that 

they do not actually owe the money. 

148. Between January 1, 2013 and December 31, 2018, MoneyGram and Ria received 

a total of at least 1,644 complaints reporting losses of $2,034,293 (including fees) about IRS and 

utility impersonation scams where the proceeds were sent from or picked up at a Walmart 

location. Between January 1, 2013 and December 31, 2018, MoneyGram received at least 1,590 

complaints with losses of $1,971,761 about IRS and utility impersonation scams; and between 

April 24, 2014 and December 31, 2018, Ria received at least 54 complaints with losses of 

$62,532 about IRS imposter scams. Since December 31, 2018, Walmart continues to be the 

subject of complaints about IRS and utility impersonation scams where the proceeds were sent 

from or picked up at a Walmart location. 

149. These types of impersonation scams typically involve a plan, program, or 

campaign to induce the purchase of goods or services using one or more telephones and more 

than one interstate telephone call. For example, Moin Gohil, Nakul Chetiwal, and Parvez Jiwani, 

three of the defendants in U.S. v. Gohil, No. 17-cr-0212 (E.D. Wis.), were involved at various 

times in such a scheme that occurred from at least January 25, 2016 until about November 24, 

2017. This scheme involved callers in India who contacted victims in the United States, 

claiming that they worked for the IRS and that the victims would be arrested immediately if they 

did not use a money transfer to pay their back taxes. In furtherance of the scheme, all three 

defendants used multiple fake IDs to pick up high-dollar transfers from Walmart locations. In 

addition, from at least May 24, 2017 until August 29, 2017, two of the three defendants 

frequently picked up high-dollar transfers, including back-to-back (consecutive) transfers, 

together at Walmart locations. This type of activity should have raised red flags because of the 

various suspicious characteristics, including the use of fake IDs, multiple transfers with highCase: 1:22-cv-03372 Document #: 62 Filed: 06/30/23 Page 72 of 85 PageID #:565
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dollar amounts, and back-to-back transfers. Even if Walmart’s employees had spotted these red 

flags, however, for years Walmart’s policy or practice was to pay out transfers even if its 

employees suspected fraud. 

150. Similarly, defendant Parmar in U.S. v. Parmar, No. 19-cr-0160 (E.D. Va.), also 

participated in a wide ranging government imposter scam that occurred from at least March 2017 

until April 2019 in which telemarketers in Pathan’s call center in India called consumers in the 

United States, claiming to be with agencies like the Federal Bureau of Investigation, Drug 

Enforcement Agency, IRS, or Social Security Administration. In order to get victims in various 

states to send money transfers, including Walmart2Walmart transfers, telemarketers would create 

a sense of urgency by telling victims they were the subject of a criminal investigation or owed 

taxes and needed to send money to avoid being arrested or prosecuted criminally, or that they 

would lose their Social Security benefits if they did not send the money. Many of the transfers in 

furtherance of this scheme, which often were for high-dollar amounts and picked up with fake 

IDs, were processed at Walmart locations. Even if Walmart’s employees had spotted these red 

flags, however, for years Walmart’s policy or practice was to pay out transfers even if its 

employees suspected fraud. 

151. In another example, as part of a plan, program, or campaign to induce the 

purchase of goods or services using one or more telephones and more than one interstate call, 

telemarketers at another call center in India targeted U.S. consumers in an IRS impersonation 

scam and also sometimes an advance-fee loan scam, using false or misleading statements to 

induce people to send a money transfer to pay back taxes or for an advance-fee loan. From at 

least July 2015 until at least February 2016, many of these money transfers were picked up by 

runners at Walmart locations. These runners frequently went to the same Walmart stores, and 

they sometimes picked up multiple transfers in the same day at the same locations without being 

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stopped. The FTC sued a Florida man, Joel Treuhaft, and his company PHLG Enterprises, LLC, 

for their conduct in connection with this scheme. FTC v. PHLG Enterprises LLC, No. 17-cv0220 (M.D. Fla.). Even if Walmart’s employees had spotted these red flags, however, for years 

Walmart’s policy or practice was to pay out transfers even if its employees suspected fraud. 

152. In another plan, program, or campaign involving a twist on the IRS impersonation 

scam in February and March 2016, telemarketers contacted a consumer in Kentucky by 

telephone—typically from a telephone number with a Washington, D.C. or New York area 

code—telling her that she was owed a large tax refund, but in order to receive it, she would have 

to pay associated fees and taxes. As directed by the telemarketer, she sent at least ten 

MoneyGram transfers totaling approximately $12,508 from her local Walmart location to 

recipients in other states, sometimes even multiple transfers in the same day from a single 

Walmart location. During her transactions, no one at Walmart asked her any questions or 

provided her with any warnings even though her transfers were unusually large and frequent. 

153. In another plan, program, or campaign involving a utility scam in November 

2022, a New Jersey victim received a few telephone calls from someone claiming to be with her 

electric company. During those calls, the telemarketers told the victim that if she did not send 

money right away, her electricity would be disconnected due to nonpayment. One of the 

telemarketers claimed to be Haitian, like her, and spoke to her in her native language, which 

made his story more convincing. The victim lost $1,615 through a banned cash-to-cash money 

transfer that she sent from a Walmart location to the Dominican Republic through Western 

Union. And despite the consumer sending a high-dollar amount to a high-risk country known for 

fraud, the Walmart employee did not, as required, ask the consumer whether her transfer was 

related to telemarketing or provide her with any warnings about telemarketers or scams. At the 

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end of the transaction, the victim also received her receipt folded and stapled together, so any 

warnings on the receipt would not have been visible. 

154. Similarly, in another plan, program, or campaign involving a utility scam, a 

Florida victim, who is also Haitian, received more than one telephone call in February 2023 from 

two telemarketers who claimed to be with her electric company. One of the telemarketers, who 

spoke to her in her native language, induced her to make two Western Union transfers totaling 

$5,028 (including fees) on consecutive days to the Dominican Republic from the same Walmart 

location. During one of those calls, the telemarketer told her that her bill was overdue and if she 

did not transfer approximately $2,500 that day, her power would be disconnected. During 

another call the next day, the telemarketer claimed that they did not receive the first money 

transfer and again threatened to disconnect her power if she did not send a second transfer for the 

same amount that day. Both telemarketers directed the victim to go to Walmart to send the 

money transfers. During each transaction, the Walmart employee did not ask her any questions 

about the purpose of her transfer, to whom she was sending the money, or whether it was related 

to telemarketing. Nor did the Walmart employee provide her with any telemarketing or scam 

warnings. At the end of both transactions, the victim also received her receipts folded and 

stapled together, so any warnings contained on the receipts would not have been visible. 

155. These are just some examples of the many U.S. consumers who lost money 

through money transfers that were sent from or received at Walmart locations in the United 

States and that Walmart knew or consciously avoided knowing were related to government or 

utility imposter telemarketing schemes. 

Person-in-Need, Grandparent, and Emergency Scams 

156. Another telemarketing scam for which Walmart has regularly processed payments 

that it knew or consciously avoiding knowing violated the TSR is the person-in-need, 

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grandparent, and emergency scam. In a typical version of this scam, telemarketers call 

consumers located throughout the United States and proceed to impersonate family members or 

close friends, telling call recipients that they need money right away to pay for various services 

to help them get out of trouble. In numerous instances, the telemarketer references the presence 

of some “authority figure,” typically a lawyer, police officer, or doctor, claiming that the money 

is needed for services like bail or a hospital expense. In other instances, the telemarketer 

impersonates a family member, like a grandchild, or a friend. These transfers frequently exhibit 

one of more of the red flags outlined above, including the involvement of elderly and/or firsttime senders of a money transfer, high-dollar amounts (individually or in aggregate), and 

multiple money transfers in relatively short periods of time. In many instances, moreover, 

consumers are asked to send a money transfer to a location outside the United States to assist the 

person-in-need. In other instances, the transfer is sent to a money mule in the United States who 

quickly flips the transfer to a country outside the United States. After consumers send the 

requested money transfer, they often learn from the impersonated family member or friend that 

there is no emergency and they have been scammed. 

157. Between January 1, 2013 and December 31, 2018, MoneyGram and Ria received 

a total of at least 20,549 complaints reporting losses of $21,422,152 (including fees) about 

person-in-need, grandparent, or emergency scams where the money was sent from or picked up 

at a Walmart location. Between January 1, 2013 and December 31, 2018, MoneyGram received 

at least 19,035 complaints with losses of $19,386,770 about person-in-need or grandparent 

scams; and between April 24, 2014 and December 31, 2018, Ria received at least 1,514 

complaints with losses of $2,035,382 about emergency or grandparent scams. Since December 

31, 2018, Walmart continues to be the subject of complaints about person-in-need, grandparent, 

and emergency scams where the proceeds were sent from or picked up at a Walmart location. 

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158. Person-in-need, grandparent, and emergency scams typically involve a plan, 

program, or campaign to induce the purchase of goods or services using one or more telephones 

and more than one interstate telephone call. For example, in May 2022, an elderly consumer in 

Illinois received an out-of-state telephone call from a man who identified himself as the 

consumer’s nephew. The caller claimed he was being detained at an airport in Mexico because 

he was carrying more than $10,000 in cash he had not reported and needed to pay a $625 fee or 

he could not fly back to the United States. During the call, a second man, who claimed to be a 

Customs Officer, asked him to go to the nearest Walmart location to send a money transfer to 

Mexico. While at the Walmart location, the consumer, who had never sent a money transfer 

before, told Walmart’s employee that he did not know the person to whom he was sending the 

cash-to-cash money transfer—which is an obvious red flag for fraud. Despite that, the Walmart 

employee still processed the elderly consumer’s MoneyGram transfer to Mexico. The Walmart 

employee also did not, as required, ask the consumer whether his transfer was related to 

telemarketing or provide him with any warnings about telemarketers or scams. In addition, 

Walmart did not provide him with any written telemarketing or scam warnings until after his 

transaction was complete, and then, those warnings were on a long receipt, which was folded and 

stapled together by the Walmart employee, so any warnings would not have been visible. Later, 

when the consumer received another out-of-state telephone call from two men impersonating the 

Customs Officer and the same nephew again and asking for additional money, he contacted a 

family member and learned he had been scammed. 

159. In another situation involving a grandparent scam in late May 2018, an elderly 

couple in Florida lost over $1,600 by sending a Walmart2Walmart cash-to-cash money transfer 

after receiving a telemarketing call from someone impersonating their grandson and reporting 

that he had been in a car accident and needed money to avoid going to jail. The caller reported 

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having someone with him who claimed to be with the District Attorney’s Office. After sending a 

cash-to-cash money transfer from their local Walmart to South Carolina, the couple received 

another call asking for even more money and realized they had been scammed. Days later, their 

son wrote a letter to Walmart’s President and Chief Executive Officer (“CEO”) describing how 

his parents had been defrauded through Walmart’s money transfer service, complaining about 

the lack of controls and safeguards that permitted this to happen, and accusing the Walmart 

employee who paid out the transfer of either being a participant in the scam or accepting a fake 

ID. He also pointed out that criminals chose to use Walmart to commit these types of crimes. 

160. These are just some examples of the many U.S. consumers who lost money 

through money transfers that were sent from or received at Walmart locations in the United 

States and that Walmart knew or consciously avoided knowing were related to person-in-need, 

grandparent, or emergency telemarketing schemes. 

Other Telemarketing Scams 

161. Walmart has also received complaints about other scams that typically involve 

telemarketing, such as romance scams, tech support scams, Good Samaritan scams, elder abuse 

scams, and debt relief scams. These scams typically involve plans, programs, or campaigns to 

induce the purchase of goods or services using one or more telephones and more than one 

interstate telephone call, and false or misleading statements by the telemarketers to induce 

consumers to pay. Walmart has regularly processed payments for these schemes that it knew or 

consciously avoiding knowing violated the TSR. These transfers frequently exhibit one or more 

of the red flags outlined above, including the involvement of elderly and/or first-time senders of 

a money transfer, higher dollar amounts (individually or in aggregate), multiple money transfers 

sent or received in relatively short periods of time, back-to-back transfers, flipping, transfers to 

high-risk counties known for fraud, recipients using fake or out-of-state IDs, transfers between 

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senders and receivers with no apparent relationship, the use of name or address variations, and 

switching between money transfer systems. Moreover, even if Walmart’s employees have 

spotted these types of red flags, for years, Walmart’s policy or practice was to pay out transfers 

even if its employees suspected fraud. 

162. Between January 1, 2013 and December 31, 2018, MoneyGram and Ria received 

a total of at least 11,833 complaints with losses of $8,729,113 (including fees) about romance 

scams where the money was sent from or picked up at a Walmart location. Between January 1, 

2013 and December 31, 2018, MoneyGram received at least 10,192 complaints with losses of 

$7,844,700 about romance scams; and between April 24, 2014 and December 31, 2018, Ria 

received at least 1,641 complaints with losses of $884,413 about romance and online dating 

scams. During that same period, Walmart also was the subject of complaints about the following 

scams: at least 355 complaints from MoneyGram with losses of $351,857 about cyber, malware, 

or other tech support scams; at least 3,092 complaints from Ria with losses of $1,809,725 about 

Good Samaritan scams; at least 855 complaints from Ria with losses of $565,062 about elder 

abuse scams; and at least 385 complaints from Ria with losses of $256,270 about debt relief 

scams. Since December 31, 2018, Walmart continues to be the subject of complaints about 

telemarketing scams, including romance and online dating scams, tech support scams, and debt 

relief scams. 

163. In many cases, Walmart has known or consciously avoided knowing about these 

types of transfers, which often exhibit obvious red flags. For example, in March 2023, a woman 

in Colorado complained to MoneyGram about being the victim of a romance scam in which she 

lost $5,032 (including fees) by sending two $2,500 cash-to-cash money transfers to Nigeria on 

consecutive days from her local Walmart location. The scammer—who the victim originally met 

on a dating website—induced her in the course of more than one interstate telephone call to send 

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the transfers from Walmart by telling her that he was a traveling registered nurse and needed the 

money to purchase a replacement passport because his had been stolen. During her transactions, 

no one at Walmart asked her any of the required questions about the nature of her transfers or 

provided her with any of the required warnings even though she was sending unusually large 

amounts of money to Nigeria—a high-risk country known by Walmart as a common destination 

for fraud-induced money transfers, including transfers involving romance scams. At the end of 

the transaction, the victim also received her receipts folded and stapled together, so any warnings 

on the receipts would not have been visible. The victim had never sent a money transfer before 

and was not aware of the risks and scams involved with money transfers. 

164. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Walmart is violating or is about to violate laws enforced by the FTC 

because, among other things, it engaged in its unlawful acts and practices repeatedly for several 

years. Walmart persisted in these practices even after it had received notice of its obligations 

under the FTC’s MoneyGram and Western Union orders, and despite its contractual obligations 

with its providers and its awareness of the TSR Amendment. It was not until Walmart had 

received two Civil Investigative Demands from the FTC in 2017 and became aware that it was 

the subject of an FTC investigation that it made significant changes to certain of its problematic 

practices. Even so, in some cases, Walmart continues to violate laws enforced by the FTC. 

VIOLATIONS OF THE FTC ACT

165. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce,” including acts or practices involving foreign commerce 

that “cause or are likely to cause reasonably foreseeable injury within the United States” or 

“involve material conduct occurring within the United States.” 

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166. Acts or practices are unfair under Section 5 of the FTC Act if they cause or are 

likely to cause substantial injury to consumers that consumers cannot reasonably avoid 

themselves and that is not outweighed by countervailing benefits to consumers or competition. 

15 U.S.C. § 45(n). 

COUNT I 

Unfair Acts or Practices 

167. In numerous instances, in connection with providing money transfer services at its 

locations, Defendant has failed to take timely, appropriate, and effective action to detect and 

prevent fraud-induced money transfers. 

168. Defendant’s actions cause or are likely to cause substantial injury to consumers 

that consumers cannot reasonably avoid themselves and that is not outweighed by countervailing 

benefits to consumers or competition. 

169. Therefore, Defendant’s acts or practices as set forth in Paragraph 167 constitute 

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45(a), 45(n). 

VIOLATIONS OF THE TSR 

170. Congress directed the FTC to prescribe rules prohibiting abusive and deceptive 

telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101–6108. The 

FTC adopted the original TSR in 1995, extensively amended it in 2003, and amended certain 

provisions thereafter. 16 C.F.R. Part 310. 

171. Defendant and its employees have processed money transfers and provided 

related services on behalf of persons who are “sellers” or “telemarketers” engaged in 

“telemarketing,” as those terms are defined in Sections 310.2 (dd), (ff), and (gg) of the TSR. A 

“seller” means any person who, in connection with a telemarketing transaction, provides, offers 

to provide, or arranges for others to provide goods or services to a customer in exchange for 

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consideration. 16 C.F.R. § 310.2(dd). A “telemarketer” means any person who, in connection 

with telemarketing, initiates or receives telephone calls to or from a customer or donor. 16 

C.F.R. § 310.2(ff). “Telemarketing” means a plan, program, or campaign which is conducted to 

induce the purchase of goods or services or a charitable contribution, by use of one or more 

telephones and which involves more than one interstate telephone call. 16 C.F.R. § 310.2(gg). 

172. The TSR prohibits telemarketers and sellers from making a false or misleading 

statement to induce any person to pay for goods or services. 16 C.F.R. § 310.3(a)(4). 

173. The TSR also prohibits telemarketers and sellers from requesting or receiving 

payment of any fee or consideration in advance of obtaining a loan or other extension of credit 

when the seller or telemarketer has guaranteed or represented a high likelihood of success in 

obtaining or arranging a loan or other extension of credit. 16 C.F.R. § 310.4(a)(4). 

174. On December 14, 2015, the FTC published a notice that it had adopted 

amendments to the TSR, including a prohibition against using “cash-to-cash” money transfers 

for outbound and inbound telemarketing transactions. 80 Fed. Reg. 77,520 (Dec. 14, 2015). 

Since June 13, 2016, the TSR has prohibited the use of “cash-to-cash” money transfers as 

payments for goods or services offered or sold through telemarketing or charitable contributions 

solicited or sought through telemarketing. 16 C.F.R. § 310.4(a)(10). 

175. It is a violation of the TSR for any person to provide “substantial assistance or 

support” to any seller or telemarketer when that person “knows or consciously avoids knowing” 

that the seller or telemarketer is engaged in any act or practice that violates Sections 310.3(a), 

(c), or (d), or 310.4 of the TSR. 16 C.F.R. § 310.3(b). 

176. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

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unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a). 

177. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as modified by 

Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 1990, 28 U.S.C. § 2461, as 

amended, and Section 1.98(d) of the FTC’s Rules of Practice, 16 C.F.R. § 1.98(d) (2021), 

authorizes the Court to award monetary civil penalties of up to $46,517 for each violation of the 

TSR committed with actual knowledge or knowledge fairly implied. The Defendant’s TSR 

violations were committed with the knowledge required by Section 5(m)(1)(A) of the FTC Act, 

15 U.S.C. § 45(m)(1)(A). 

COUNT II 

Assisting and Facilitating Violations of the Cash-to-Cash Money Transfer Ban

178. In numerous instances, in the course of processing money transfers, Defendant 

and its employees have provided substantial assistance or support to sellers or telemarketers who 

Defendant or its employees knew or consciously avoided knowing had accepted cash-to-cash 

money transfers as payments for goods or services offered or sold through telemarketing or for 

charitable contributions solicited or sought through telemarketing in violation of Section 

310.4(a)(10) of the TSR, 16 C.F.R. § 310.4(a)(10). 

179. Therefore, Defendant’s acts or practices, as set forth in Paragraph 178 violate the 

TSR, 16 C.F.R. §310.3(b). 

COUNT III 

Assisting and Facilitating False or Misleading Statements 

180. In numerous instances, in the course of processing money transfers, Defendant 

and its employees have provided substantial assistance or support to sellers or telemarketers who 

Defendant or its employees knew or consciously avoided knowing had induced consumers to pay 

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for goods or services or charitable contributions through the use of false or misleading statements 

in violation of Section 310.3(a)(4) of the TSR, 16 C.F.R. § 310.3(a)(4). 

181. Therefore, Defendant’s acts or practices, as set forth in Paragraph 180 violate the 

TSR, 16 C.F.R. §310.3(b). 

COUNT IV 

Assisting and Facilitating Advance-Fee Loans

182. In numerous instances, in the course of processing money transfers, Defendant 

and its employees have provided substantial assistance or support to sellers or telemarketers who 

Defendant or its employees knew or consciously avoided knowing had requested or received 

payment of a fee or consideration in advance of consumers obtaining a loan when the seller or 

telemarketer has guaranteed or represented a high likelihood of success in obtaining or arranging 

a loan for a person in violation of Section 310.4(a)(4) of the TSR, 16 C.F.R. § 310.4(a)(4). 

183. Therefore, Defendant’s acts or practices, as set forth in Paragraph 182 violate the 

TSR, 16 C.F.R. §310.3(b). 

CONSUMER INJURY

184. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendant’s violations of the FTC Act and the TSR. Absent injunctive relief 

by this Court, Defendant is likely to continue to injure consumers and harm the public interest. 

PRAYER FOR RELIEF

Wherefore, Plaintiff requests that the Court: 

 A. Enter a permanent injunction to prevent future violations of the FTC Act and the 

TSR by Defendant; 

 B. Award Plaintiff monetary civil penalties for each violation of the TSR; 

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 C. Award monetary and other relief within the Court’s power to grant, including 

rescission or reformation of contracts, the refund of money, the return of property, the 

payment of damages, public notification, or other relief necessary to redress injury to 

consumers; and 

 D. Award any additional relief as the Court determines to be just and proper. 

Dated: June 30, 2023 Respectfully submitted, 

 

 /s/ Karen D. Dodge 

 KAREN D. DODGE 

 PURBA MUKERJEE 

 MATTHEW G. SCHILTZ 

 RACHEL F. SIFUENTES 

 Attorneys for Plaintiff 

 Federal Trade Commission 

 230 South Dearborn Street, Suite 3030 

 Chicago, Illinois 60604 

 (312) 960-5634 (telephone) 

(312) 960-5600 (facsimile) 

Case: 1:22-cv-03372 Document #: 62 Filed: 06/30/23 Page 85 of 85 PageID #:578