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Former MoneyGram CCO Settles with FinCEN and US Attorney’s Office

By Jack Hayes & Evan Abrams on May 12, 2017
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On May 4, 2017, the Financial Crimes Enforcement Network (“FinCEN”) of the US Department of the Treasury and the US Attorney’s Office for the Southern District of New York announced an agreement with former MoneyGram Chief Compliance Officer Thomas Haider to settle claims under the Bank Secrecy Act (“BSA”). FinCEN initially assessed a $1 million civil monetary penalty against Mr. Haider in December of 2014, which the US Attorney for the South District of New York then sought to enforce in federal court. The case was transferred to the US District Court for the District of Minnesota, where Mr. Haider settled the allegations for $250,000. Under the agreement, Mr. Haider will also be barred from similar jobs for three years. The settlement marks the end of a long running and closely watched money laundering case and, according to a FinCEN spokesman, is one of the largest fines ever imposed against an individual related to failures or omissions under BSA requirements for a financial institution. In November 2012, MoneyGram entered into a separate deferred prosecution agreement with the US Department of Justice, in which it agreed to forfeit $100 million and retain an independent compliance monitor.

As outlined in the FinCEN press release, Mr. Haider admitted responsibility for: (1) failing to take action after being presented with information that certain MoneyGram outlets engaged in consumer fraud schemes, (2) failing to implement a policy to terminate outlets posing a high risk of fraud, and (3) overseeing the MoneyGram anti-money money laundering (“AML”) compliance program with alleged deficiencies that prevented appropriate filing of suspicious activity reports (“SARs”).

The case was particularly notable due to its focus on individual, rather than corporate, wrongdoing. Recent FinCEN actions against similar companies, such as Western Union, have not resulted in individual liability. According to a statement from Jamal El-Hindi, the Acting Director of FinCEN, “holding [Mr. Haider] personally accountable strengthens the compliance profession by demonstrating that behavior like this is not tolerated within the ranks of compliance professionals.” Mr. Haider asserted that the BSA did not provide for individual liability, but Judge David S. Doty of the US District Court for the District of Minnesota rejected that argument and found the BSA permitted civil liability for corporate officers and employees responsible for designing and overseeing AML compliance programs.

Many commentators attributed this result to increased focus by the US government on pursuing individuals for wrongdoing, as outlined in a September 2015 memo from former US Deputy Attorney General Sally Yates. Although FinCEN has initiated cases against individuals since first fining Haider in 2014, there has not been a flood of such actions.

Photo of Jack Hayes Jack Hayes

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and…

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and post-closing acquisition export compliance due diligence, export control audits, and assessments of compliance obligations and risks in accordance with relevant international trade regulations. He also provides guidance on brokering requirements and reporting obligations for certain fees, commissions, and political contributions related to sales of defense articles and defense services, prepares export and reexport license and agreement applications for submission, undertakes commodity jurisdiction and export classification analyses of items and services under the ITAR and EAR, drafts registration material change notifications, and develops compliance policies, programs, and training materials.

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Photo of Evan Abrams Evan Abrams

Evan Abrams counsels multinational corporations, financial institutions, and individuals on various international regulatory and compliance matters. He assists foreign and domestic companies in navigating national security reviews by the Committee on Foreign Investment in the United States (CFIUS). He has represented companies in…

Evan Abrams counsels multinational corporations, financial institutions, and individuals on various international regulatory and compliance matters. He assists foreign and domestic companies in navigating national security reviews by the Committee on Foreign Investment in the United States (CFIUS). He has represented companies in industries including semiconductors, metals, and digital security. Evan’s anti-money laundering (AML) practice focuses on helping financial institutions comply with federal and state AML rules, particularly money transmitters and entities involved in creating, exchanging, or dealing in cryptocurrencies and tokens. Evan counsels clients in a variety of export controls and sanctions matters related to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and various sanctions programs under US and international law. In addition, Evan routinely assists clients on anti-corruption investigations and enforcement actions.

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  • Posted in:
    Corporate Governance and Compliance
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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