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Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 1 of 16 PageID #:100
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`Civil Action No. 09-cv-6576
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`FEDERAL TRADE COMMISSION,
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`Plaintiff,
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`v.
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`MONEYGRAM INTERNATIONAL, INC.,
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`Defendant.
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`FTC’S UNOPPOSED MOTION FOR ENTRY OF STIPULATED ORDER
`FOR COMPENSATORY RELIEF AND MODIFIED ORDER
`FOR PERMANENT INJUNCTION
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`Plaintiff, the Federal Trade Commission (“FTC”), moves this Court pursuant to Local
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`Rule 37.1, Part XII of the Stipulated Order for Permanent Injunction and Final Judgment entered
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`by the Court in this matter on October 21, 2009 (“2009 Order” or “Order”), and the Court’s
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`inherent authority, to enter the attached Stipulated Order for Compensatory Relief and Modified
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`Order for Permanent Injunction. Defendant, MoneyGram International, Inc. (“MoneyGram”),
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`has agreed to the entry of the Stipulated Order for Compensatory Relief and Modified Order for
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`Permanent Injunction, and has represented to the FTC that it does not oppose this motion. In
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`support of the motion, the FTC states the following:1
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`I.
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`BACKGROUND
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`MoneyGram offers money transfer services to consumers worldwide through a network
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`of approximately 350,000 agent locations in more than 200 countries and territories. Consumers
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`1
`Because the FTC and MoneyGram have reached a resolution of the allegations in
`this motion, the FTC is not filing any affidavit or evidence in support of this motion.
`MoneyGram neither admits nor denies any of the FTC’s allegations set forth in this motion.
`1
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`wishing to send funds using MoneyGram’s money transfer system may initiate a transaction in
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`person, online, through a mobile device, or at a self-service kiosk located at a MoneyGram agent
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`location. For many years, money transfers have been a preferred method of payment for
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`fraudsters because the money sent through MoneyGram’s system can be picked up quickly at
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`many agent locations around the world, and consumers typically are unable to get their money
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`back once the funds have been paid out. In addition, for many years, the perpetrators often have
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`been afforded anonymity when receiving money though MoneyGram, including, in some
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`instances, by having the ability to pick up transfers without presenting identifications (“IDs”) or
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`by using fake names, addresses, and IDs.
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`On October 21, 2009, the Honorable John F. Grady entered the 2009 Order (Dkt. No. 13)
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`against MoneyGram, which resolved the allegations in the FTC’s Complaint (Dkt.
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`No. 1). The Complaint alleged that, between at least 2004 and 2008, MoneyGram had assisted
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`fraudulent telemarketers by failing to take timely, appropriate, and effective measures to address
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`fraud-induced money transfers in its system. The 2009 Order prohibits MoneyGram from,
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`among other things, failing to: establish, implement, and maintain a comprehensive anti-fraud
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`program that is reasonably designed to protect U.S. and Canadian consumers (Section I); conduct
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`thorough due diligence on prospective agents and ensure its written agreements require agents to
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`have effective anti-fraud policies and procedures in place (Section II); adequately monitor its
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`agents by, among other things, providing appropriate and ongoing training, recording all
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`complaints, reviewing transaction activity, investigating agents, taking disciplinary action against
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`problematic agents, and ensuring its agents are aware of their obligations to detect and prevent
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`fraud and to comply with MoneyGram’s policies and procedures (Section III); and share
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`consumer complaint information with the FTC for inclusion in the Consumer Sentinel Network,
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`2
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`a database of consumer fraud complaints maintained by the FTC and available to law
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`enforcement (Section IV).2
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`As a result of the 2009 Order, MoneyGram has made some enhancements to its agent
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`oversight and anti-fraud program, but as this motion demonstrates, it has not been in full
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`compliance with the terms of the 2009 Order. By agreeing to a Stipulated Order for
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`Compensatory Relief and Modified Order for Permanent Injunction, MoneyGram has committed
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`to address deficiencies in its anti-fraud program, as well as to improve and expand its program to
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`protect consumers worldwide from consumer fraud involving its money transfer system.
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`II. MONEYGRAM FAILED TO FULLY COMPLY WITH THE TERMS OF THE
`2009 ORDER
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`For years, MoneyGram failed to take all of the steps necessary—and required by the
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`2009 Order—to detect and prevent consumer fraud over its money transfer system.3 As a result,
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`MoneyGram’s system continued to be used by fraudsters around the world to obtain money from
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`their victims. In some cases, MoneyGram failed to adopt and implement anti-fraud policies and
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`procedures consistent with the Order, while in other cases, it failed to properly train its agents, to
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`promptly investigate agents that were the subject of fraud complaints, to take the required
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`disciplinary actions against all of the problematic agents, and to conduct the required background
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`checks to avoid installing agents that might become involved or complicit in frauds. It also
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`2
` In November 2012, MoneyGram also entered into a five-year Deferred
`Prosecution Agreement (“DPA”) with the Department of Justice, in which MoneyGram admitted
`that it had criminally aided and abetted wire fraud and failed to maintain an effective Anti-
`Money Laundering (“AML”) program relating to consumer fraud from 2004 through 2009. As
`part of the DPA, MoneyGram also agreed to implement enhanced compliance obligations with
`respect to its anti-fraud and AML programs. The five-year term of the DPA was scheduled to
`expire in November 2017, but it has since been extended multiple times. United States v.
`MoneyGram Int’l Inc., No. 12-CR-00291 (M.D. Pa. Nov. 9, 2012).
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`MoneyGram’s anti-fraud program is designed, implemented, and administered
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`primarily within the United States.
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`3
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`failed to record, as well as to share with Consumer Sentinel, all consumer complaints it received
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`about fraud-induced money transfers. Significantly, moreover, although MoneyGram
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`implemented a new interdiction system in April 2015 that was supposed to enhance its ability to
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`automatically hold and prevent the payout of money transfers that likely were fraud-induced, this
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`interdiction system failed to function properly from approximately April 2015 through October
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`2016, thereby failing to prevent millions of dollars in fraud-induced money transfers.
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`Each of these violations of the 2009 Order is detailed below. Together, the violations
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`caused significant consumer losses.
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`A. MoneyGram Failed to Promptly Investigate and then Discipline Agent
`Locations with High Levels of Consumer Fraud
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`In numerous instances, MoneyGram failed to promptly investigate and take the required
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`disciplinary actions against some of its agent locations—especially large chain agents—that
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`exhibited high levels of consumer fraud.
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`1.
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`MoneyGram’s Failure to Promptly Investigate Certain Agents
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`The 2009 Order requires MoneyGram to conduct timely consumer fraud investigations of
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`any agent location that meets one of the following thresholds: (1) has received two or more fraud
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`complaints in a thirty-day period; (2) has fraud complaints amounting to five percent or more of
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`the location’s total received transactions, in numbers or dollars, calculated on a monthly basis; or
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`(3) has displayed any unusual or suspicious money transfer activity that cannot reasonably be
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`explained or justified. (Section III.B.3-4.) MoneyGram is required to complete an investigation
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`within 14 or 30 days, depending upon which threshold triggered the investigation. If the
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`investigation is not completed within the required time, then MoneyGram must suspend the
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`agent location until the investigation is completed.
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`4
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`In some instances, MoneyGram failed to conduct the reviews required by the 2009 Order
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`of agent locations that satisfied these thresholds, or to suspend agents when investigations were
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`not completed on time. For example, from approximately March 2015 until at least March 2016,
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`MoneyGram did not conduct the required individual reviews of agent locations for certain large
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`chain agents that met the review thresholds and did not even consider whether any type of
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`disciplinary action was necessary at those locations. By failing to conduct individual reviews of
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`all locations meeting the Order’s thresholds, MoneyGram violated Section III.B of the Order.
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`2.
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`MoneyGram’s Failure to Promptly Discipline Certain Agents
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`In many instances, MoneyGram also failed to promptly discipline certain agent locations
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`as required by the terms of the 2009 Order. This was especially the case with individual
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`locations of large chain agents.
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`Under the Order, MoneyGram is required to terminate, suspend, or restrict locations that
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`have failed to take appropriate steps to prevent fraud-induced money transfers. It also is required
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`to terminate locations that “may be complicit” in fraud-induced money transfers. (Section
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`III.B.5.b.) Nevertheless, MoneyGram failed to promptly terminate, suspend, or restrict certain
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`agent locations that had high levels of fraud and that had failed to take appropriate steps to
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`prevent fraud, including recording required information (such as consumers’ IDs and
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`biographical information), training and overseeing employees, monitoring money transfer
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`activity, and refusing to pay out suspicious transfers that likely were fraud-induced. In some
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`instances, MoneyGram had agent locations that likely were complicit in frauds, but MoneyGram
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`did not adequately comply with the Order’s prompt termination requirement.
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`Although MoneyGram often took disciplinary actions, including terminations, against
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`lower volume, “mom and pop” agents with high fraud levels, it treated large chain agents
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`5
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`differently and sometimes failed to take the required disciplinary actions against certain chain
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`agent locations that had high levels of fraudulent activity. For example, MoneyGram did not
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`begin placing any restrictions on locations of one large chain agent until approximately mid-
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`2013, despite the following facts: (1) the chain was the subject of substantially more consumer
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`fraud complaints than any other MoneyGram agent worldwide, including other high-volume
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`agents; (2) the chain had locations with high levels of fraud and suspicious activities, including
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`some locations with fraud rates of more than 25 percent, or even 50 percent, of their money
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`transfer activity—when taking into account confirmed and linked fraud; and (3) the chain had
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`failed to take appropriate steps to prevent fraud at its locations. Even by mid-2013, MoneyGram
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`had only established a pilot program for restricting that chain’s locations. In addition, before
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`approximately May 2017, MoneyGram did not suspend any locations of that particular chain
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`agent, even where that agent’s locations had high levels of fraud and failed to provide the
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`required consumer fraud training to their employees, or otherwise demonstrated a pattern of non-
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`compliance with MoneyGram’s policies and procedures.
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`Information contained in MoneyGram’s own records demonstrates that it has been aware
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`for years of high levels of fraud and suspicious activities involving particular agents—including
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`large chain agents—yet it sometimes failed to take prompt disciplinary action against those
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`agents as required by the 2009 Order. These records demonstrate a range of suspicious
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`activities, including, but not limited to, the following: (1) high numbers and patterns of
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`complaints; (2) spikes in the number of money transfers received; (3) money transfer amounts
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`that exceed the average transfer amount; (4) data integrity issues (issues relating to the recording
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`of ID numbers, dates of birth, or other information about recipients); (5) payouts within minutes
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`after the money transfers were sent; (6) same ID or addresses used by multiple receivers;
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`6
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`(7) flipping (shortly after receiving funds, a large portion of the money is sent to another
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`recipient); (8) structuring of transactions; and (9) substantial transfers to high-risk countries
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`known for fraud. Under the terms of the 2009 Order, these types of suspicious activities
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`triggered a duty by MoneyGram to investigate and, depending on the findings, impose some type
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`of disciplinary action.
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`In fact, MoneyGram established different standards for disciplinary actions involving
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`large chain agents, even though that practice finds no support in the terms of the 2009 Order. As
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`noted, the 2009 Order requires the termination of any agent location that “may be complicit” in
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`fraud-induced money transfers. Consistent with that standard, MoneyGram’s “Global Anti-
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`Fraud Policy and Response Program” generally provides that if MoneyGram finds that the agent
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`“may be complicit,” it must be terminated. However, with chain agents, which MoneyGram has
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`defined as agents with ten or more locations, MoneyGram’s policy only requires termination “if
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`the Chain Agent itself is complicit” in the fraud. (Emphasis added.) That is a different standard
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`than the one in Section III of the Order. The Order defines a “MoneyGram Agent” as “any
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`person authorized to sell money transfer services marketed by” MoneyGram, and each location
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`constitutes a separate agent for purposes of the Order. (Defn. A.) As a result, the Order requires
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`that the complicity assessment be made separately with respect to each chain agent location. By
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`failing to do that, MoneyGram violated the terms of the Order. In some cases, moreover,
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`although MoneyGram’s contracts with large chain agents typically provide MoneyGram with the
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`authority to suspend money transfer services “until remedial controls have been implemented” at
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`their locations, they do not provide MoneyGram with the authority to terminate agent locations
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`as a remedial measure, even though the Order requires MoneyGram to terminate any location
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`that may be complicit in fraud.
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`7
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`The written guidelines used by MoneyGram’s Financial Intelligence Unit (“FIU”), which
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`is the primary unit responsible for conducting consumer fraud investigations and taking (or
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`recommending) disciplinary actions against agents in accordance with the 2009 Order, also
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`demonstrate that MoneyGram established standards for disciplinary actions that did not comply
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`with the 2009 Order’s requirements. These guidelines, which were dated April 11, 2013,
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`required agents to have unreasonably high fraud rates before they would be subject to suspension
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`or termination, and also set a higher standard for terminations due to complicity.
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`For example, these FIU guidelines provided for suspension of an agent location when
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`fraud activity represents “greater than 75%” of the location’s transactions, and termination of an
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`agent location when fraud activity represents “greater than 90%” of the transactions. (Emphasis
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`added.) These guidelines do not comply with the 2009 Order, which requires MoneyGram to
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`terminate, suspend, or restrict agents that have not been “taking appropriate steps to prevent”
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`fraud-induced money transfers. That standard is satisfied long before the point at which greater
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`than 75 percent of an agent’s transactions are determined to be for fraud. The guidelines further
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`indicate that terminations are appropriate where there is “[a] clear indication of Agent
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`complicity.” The standard for terminating agent locations in the 2009 Order, however, requires
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`termination when there may be complicity at an agent location, long before fraud activity reaches
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`greater than 90 percent or there otherwise is “a clear indication of Agent complicity.”
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`B. MoneyGram Failed to Properly Monitor Agents’ Money Transfer Activity
`and Maintain Appropriate Technical Safeguards to Prevent Fraud
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`The 2009 Order requires MoneyGram to implement a comprehensive anti-fraud program
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`that includes appropriate and adequate monitoring of agent activity related to the prevention of
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`fraud-induced money transfers. (Section I.D.4.) Despite the Order’s requirements, MoneyGram
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`failed to adequately monitor and prevent the money transfer activity of recipients of fraud-
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`8
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`induced money transfers, including recipients who had been the subject of one or more consumer
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`fraud complaints, or who otherwise had engaged in suspicious activity or activity linked to fraud-
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`induced money transfers. In some cases, these recipients were members of fraud rings who
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`conducted numerous suspicious transfers at one or more agent locations within a particular
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`geographic area. Their money transfers also exhibited other suspicious characteristics indicative
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`of fraud, such as multiple transfers at the same or different locations on the same day within a
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`short period of time, large-dollar amounts or structured money transfers, and suspicious
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`biographical information, such as shared or fake addresses or IDs. By adequately monitoring
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`this activity, MoneyGram should have been able to prevent these losses.
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`In addition, although MoneyGram’s anti-fraud program is required to have the
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`“administrative, technical, and physical safeguards appropriate to Defendant’s size and
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`complexity, and the nature and scope of Defendant’s activities” (Section I.D), MoneyGram
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`failed to maintain those technical safeguards for at least an eighteen-month period from April
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`2015 through October 2016. During this time, MoneyGram’s interdiction system, which was
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`supposed to block fraud-induced money transfers, experienced serious technical problems and
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`was ineffective at blocking a substantial number of such transfers. As a result, MoneyGram
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`allowed individuals that it knew, or should have known, were using its system for fraud to obtain
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`the proceeds of their frauds.
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`In response to the technical problems, MoneyGram failed to add individuals who had
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`received, or were linked to, fraud-induced money transfers to its Internal Watch List, which is
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`used for blocking fraud-induced money transfers in its system. Consequently, known fraudsters
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`were able to continue using the system to obtain money from their victims. By failing to provide
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`the necessary technical safeguards during this period, MoneyGram violated the Order.
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`9
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`C. MoneyGram Failed to Properly Train All Agents
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`The 2009 Order requires MoneyGram to provide appropriate and adequate ongoing
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`education and training for all of its agents on how to detect and prevent consumer fraud (Sections
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`I.D.3, III.A), but for years, MoneyGram sometimes failed to provide the required training.
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`Although MoneyGram recognizes that its agents and their employees are the “first line of
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`defense” in preventing fraud, it provided only limited training to certain agents and also failed to
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`ensure that certain agents were properly training their own employees.
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`In many cases, MoneyGram adopted the train-the-trainer approach and relied upon its
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`agents to provide training to their employees responsible for processing money transfers.
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`MoneyGram failed, however, to ensure that the employees of agents responsible for sending and
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`paying out money transfers were adequately trained about consumer fraud, including with
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`respect to detecting and preventing fraud, properly recording consumers’ biographical
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`information and IDs, and addressing suspicious activities. For example, an audit of 397
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`locations of a large chain agent in 2014 disclosed that 1,863 “primary and secondary” employees
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`responsible for processing money transfers had not had either initial or ongoing training, and 68
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`percent of secondary employees had not had any training at all. Moreover, even after
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`MoneyGram began a new audit procedure in 2015, which involved not only providing advance
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`notice of store audits, but also warning about the risk of suspension for non-compliance, the
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`audits continued to find that some chain locations had untrained employees and other non-
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`compliance issues. Even so, MoneyGram did not immediately suspend those locations, but
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`instead gave them at least thirty days after the audit to train employees and address the non-
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`compliance issues.
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`MoneyGram also failed to ensure that high-fraud agent locations that were required to
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`conduct consumer fraud training as a remedial measure had promptly trained their employees to
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`prevent future consumer fraud at those locations. In some cases, agents failed for months to
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`conduct, or prove that they had conducted, the required consumer fraud training at their
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`locations, even though the Order requires MoneyGram to take “[p]rompt disciplinary action
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`against MoneyGram Agents…, including [by] requiring mandatory fraud training.” (Section
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`I.D.5.) Despite this requirement, MoneyGram permitted high-fraud agent locations to continue
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`to have unfettered access to its system for months before taking further corrective action, such as
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`by restricting them, to address their failure to train employees. According to MoneyGram’s
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`internal guidelines, MoneyGram only recommended restricting a location’s ability to process
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`money transfers if it was “[u]nable to complete fraud training within 100 calendar days.” That is
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`not “prompt disciplinary action” under the terms of the 2009 Order, as it enabled further fraud to
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`be perpetrated through the agent’s untrained employees for another 100 days.
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`D. MoneyGram Failed to Conduct Thorough Due Diligence of All Agents
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`Although MoneyGram is required under the 2009 Order to conduct “thorough due
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`diligence” on prospective agents in order to avoid installing agents that might become involved
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`or complicit in frauds, in some cases, it failed to do so. Under the Order, MoneyGram’s due
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`diligence must include, but not be limited to, verifying government-issued IDs, conducting
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`reasonable background checks, conducting individualized assessments of applications, and
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`conducting reasonable inquiries to ensure that prospective agents were not previously closed
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`down by another money services business for fraud-related reasons. (Section II.A.) In some
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`instances, MoneyGram’s due diligence failures resulted in the installation of agents that had been
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`closed by Western Union due to fraud or had backgrounds indicating that they were at risk for
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`11
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`becoming involved or complicit in processing fraud-induced money transfers. MoneyGram also
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`sometimes failed to maintain records demonstrating that it had conducted the required due
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`diligence.
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`E. MoneyGram Failed to Record All Consumer Complaints
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`The Order requires MoneyGram to record all complaints relating to fraud-induced money
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`transfers, and to share information about them with the FTC’s Consumer Sentinel Network
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`unless a consumer requests that the information not be shared with law enforcement.4 (Sections
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`III.B.1 and IV.B.) Despite these requirements, MoneyGram has, in some cases, failed to record,
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`and ultimately share with the FTC, information that it has received about fraud-induced money
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`transfers.5 In addition, MoneyGram has failed to provide to Consumer Sentinel all of the
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`complaints it received and recorded in its complaint database relating to U.S. and Canadian
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`consumers. These failures to record and to share complaint information with Consumer Sentinel
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`violate the Order.
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`III. CONSUMER COMPLAINTS ABOUT FRAUD-INDUCED MONEY TRANSFERS
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`MoneyGram maintains a database of complaints it receives about fraud-induced money
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`transfers. Based on information in that database, between January 1, 2013 and April 30, 2018,
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`MoneyGram received at least 295,775 complaints about fraud-induced money transfers. These
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`complaints relate to a variety of scams, including, but not limited to, online or Internet purchase
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`4
`In instances where consumers have requested that their information not be shared
`with law enforcement, MoneyGram has been providing the FTC with their anonymized
`complaint information.
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`This failure affects multiple aspects of MoneyGram’s anti-fraud program, as well
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`as compliance with the Order, since the complaint information is supposed to be used for
`purposes of identifying, investigating, and taking disciplinary actions against agents. It also is
`important for MoneyGram to share this information with the FTC, so that it can be made
`available to other law enforcement agencies that have access to Consumer Sentinel and use it for
`law enforcement purposes.
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`12
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`scams, person-in-need scams, investment scams, romance scams, and lottery or prize scams.
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`Approximately 77 percent of the complaints in the database are from U.S. consumers and
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`approximately 6 percent of the complaints are from Canadian consumers.
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`Moreover, a discrete set of agents processed most of the transactions related to the
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`consumer fraud complaints. In fact, based on MoneyGram’s complaints, only approximately
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`3.71 percent of its agents worldwide (approximately 13,000 locations) have received five or
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`more fraud complaints since January 1, 2013, yet those agents account for approximately 84.48
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`percent of all complaints to MoneyGram.
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`The complaints in MoneyGram’s database represent only a small percentage of the actual
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`fraud perpetrated through its system because most victimized consumers do not complain
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`directly to MoneyGram. In addition, as noted above, MoneyGram has not included information
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`in its database about all of the complaints it has received about fraud-induced money transfers.
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`Therefore, MoneyGram’s database understates the actual amount of fraud through its money
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`transfer system.
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`Despite MoneyGram’s obligations to implement and maintain adequate and effective
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`anti-fraud and AML programs designed to detect and prevent consumer fraud pursuant to the
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`2009 Order and the DPA, between 2012 and 2016, consumer fraud complaints to MoneyGram
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`more than doubled, from approximately 26,485 complaints in 2012 to approximately 75,628
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`complaints in 2016. During the FTC’s investigation of MoneyGram’s compliance with the 2009
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`Order, MoneyGram began taking more meaningful disciplinary actions against agents—
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`especially large chain agents—and complaints went down significantly in 2017.
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`13
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`IV. RELIEF REQUESTED
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`Without admitting or denying the allegations described herein, and in order to resolve
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`those allegations, MoneyGram has agreed to the entry of a monetary judgment for compensatory
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`relief in the amount of $125 million. Courts possess the inherent authority to enforce compliance
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`with their orders. FTC v. Asia Pac. Telecom, Inc., 788 F. Supp. 2d 779, 789 (N.D. Ill. 2011).
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`Obedience to judicial orders is a fundamental expectation of our legal system. In particular,
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`injunctions issued by a court of competent jurisdiction must be obeyed until withdrawn or
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`vacated. W.R. Grace & Co. v. Local Union 759, 461 U.S. 757, 766 (1983); APC Filtration, Inc.
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`v. Becker, 2010 U.S. Dist. LEXIS 125871, at *3 (N.D. Ill. Nov. 30, 2010). Courts have “wide
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`discretion in fashioning an equitable remedy for civil contempt.” McGregor v. Chierico, 206
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`F.3d 1378, 1385 n.5 (11th Cir. 2000) (citing United States v. City of Miami, 195 F.3d 1292, 1298
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`(11th Cir. 1999)). Where consumers suffer losses as a result of the violation of an FTC
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`injunction, compensatory relief is the appropriate remedy. FTC v. Trudeau, 662 F.3d 947, 950
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`(7th Cir. 2011); McGregor, 206 F.3d at 1388-89.
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`MoneyGram also has agreed to the entry of an order modifying the 2009 Order to include
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`a broader range of relief, including a requirement to interdict (or block) the transfers of known
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`fraudsters and provide refunds for non-compliance with certain policies or procedures. This
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`relief is necessary to address MoneyGram’s non-compliance with the Order, including
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`deficiencies in its anti-fraud program. This Court has the power to modify the terms of its
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`injunctions in the event that changed circumstances require a modification. See McGregor, 206
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`F.3d at 1386, n.9; United States v. Oregon, 769 F.2d 1410, 1416 (9th Cir. 1985). For the reasons
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`described above, there has been a change in circumstances, which warrants expanding the
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`14
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`Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 15 of 16 PageID #:114
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`injunctive relief to ensure that MoneyGram is maintaining an adequate and comprehensive anti-
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`fraud program designed to protect consumers.
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`V.
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`CONCLUSION
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`For the foregoing reasons, the FTC respectfully requests that the Court enter the
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`Stipulated Order for Compensatory Relief and Modified Order for Permanent Injunction.
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`MoneyGram has represented to the FTC that it does not oppose this motion.
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`Dated: November 8, 2018
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`Respectfully Submitted,
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`/s/ Karen D. Dodge
`KAREN D. DODGE
`JOANNIE T. WEI
`Attorneys for Plaintiff
`Federal Trade Commission
`230 South Dearborn Street, Suite 3030
`Chicago, Illinois 60604
`(312) 960-5634 (telephone)
`(312) 960-5600 (facsimile)
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`15
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`Case: 1:09-cv-06576 Document #: 14 Filed: 11/08/18 Page 16 of 16 PageID #:115
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`CERTIFICATE OF SERVICE
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`I, Karen D. Dodge, an attorney, hereby certify that, on November 8, 2018, I caused to be
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`served a true copy of the foregoing FTC’s Unopposed Motion for Entry of Stipulated Order
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`for Compensatory Relief and Modified Order for Permanent Injunction, with written
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`consent, by electronic mail on:
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`DAVID M. ZINN
`STEVEN M. CADY
`Attorneys for Defendant
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, D.C. 20005-5901
`dzinn@wc.com
`scady@wc.com
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`/s/ Karen D. Dodge
`KAREN D. DODGE
`Attorney for Plaintiff
`Federal Trade Commission
`230 South Dearborn Street, Suite 3030
`Chicago, Illinois 60604
`(312) 960-5634 (telephone)
`(312) 960-5600 (facsimile)
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