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State AML Enforcement: What Money Transmitters Need to Know About the RamadPay Consent Order

By Keith J. Barnett on August 26, 2026
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In this episode of Payments Pros, host Keith Barnett examines a June 2026 multistate consent order issued jointly by Colorado and Texas against RamadPay, a Minnesota-based money transmitter specializing in international transfers between the U.S. and Africa.

Keith walks through the three core compliance failures identified during a coordinated examination: untimely filing of CTRs and CMIRs, deficiencies in the company’s AML/CFT program particularly around agent monitoring and independent program reviews, and violations of the FTC’s Safeguards Rule related to inadequate device and software inventory management. He emphasizes that regulators flagged repeat deficiencies from prior examinations, underscoring the critical importance of actually remediating issues identified by independent auditors. Keith also details the corrective requirements imposed on RamadPay, including a $200,000 penalty, mandatory hiring of a third-party compliance consultant, enhanced AML/CFT monitoring, and quarterly progress reporting to both states.

The episode closes with a reminder that state regulators are increasingly scrutinizing cybersecurity and data governance alongside BSA/AML compliance in money transmitter examinations.


Transcript: State AML Enforcement: What Money Transmitters Need to Know About the RamadPay Consent Order (PDF)

Photo of Keith J. Barnett Keith J. Barnett

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts…

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts, state courts, and before arbitration and administrative law panels in the financial services industry.

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  • Posted in:
    Administrative and Regulatory, Banking, Finance and Securities, Privacy and Cybersecurity
  • Blog:
    Regulatory Oversight
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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