On June 18, the Texas Department of Banking and the Colorado Division of Banking entered a consent order with a money transmitter, imposing a $200,000 administrative penalty following a multi-state examination that identified alleged BSA/AML violations. The examination found that the money transmitter had allegedly failed to timely file currency transaction reports and reports of transportation of currency or monetary instruments. The examination also identified alleged deficiencies in the company’s implementation of its Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) program, including issues related to monitoring domestic agents and ensuring adequate independent reviews, as well as violations of requirements for safeguarding consumer financial information under 16 C.F.R. part 314, including a failure to adequately identify and manage devices and software systems. The money transmitter did not admit any wrongdoing, violations, or implications of fact in connection with the order.

Under the terms of the order, the money transmitter agreed to engage an independent, third-party compliance consultant within 90 days to augment its AML/CFT program, including quarterly reviews of corrective actions, suspicious activity report processes, and independent testing of transaction data. The money transmitter also agreed to strengthen its AML/CFT monitoring systems and due diligence procedures, institute a more robust data integrity program to ensure accurate customer information consistent with FinCEN’s “Know Your Customer” guidelines, and undergo an independent review of its AML/CFT program at least annually pursuant to 31 C.F.R. § 1022.210. The order further requires the money transmitter to submit quarterly written progress reports and maintain the compliance consultant engagement for one year, subject to a possible one-year extension at the states’ discretion, and to pay the $200,000 penalty, divided evenly between the two states.