Civil Enforcement Information - MoneyGram Payment Systems, Inc.

Date issued: Apr. 29 2021

You've hit a wall. Sign in, sign up for unlimited access, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.

TURBOFAC Commentary (483 words)


1) With a few exceptions discussed below, there the MoneyGram case is similar to other enforcement actions against remittance industry participants. Compare Western Union Financial Services, Inc.. The legal bases for the penalty are straightforward.

As it relates to payments made to or behalf of blocked persons, U.S. person payment remitters violate sanctions regulations when they process payments in which a blocked person has an “interest”. Here, OFAC notes that a number of violations arose from payments made to blocked prisoners held in U.S. facilitates. A prisoner held in the U.S. is necessarily a “U.S. person” for the purposes of sanctions regulations, and this is the case even with respect to foreign nationals that are only in the U.S. because they have been extradited or were arrested upon arrival and subsequently held in the U.S. against their will. Compare