SUPERINTENDENT ADRIENNE A. HARRIS ANNOUNCES THAT DFS HAS IMPOSED A PENALTY OF $8.25 MILLION ON MONEYGRAM FOR COMPLIANCE FAILURES Moneygram Failed to Properly Supervise Agents Engaging in Suspicious Transactions to China

Wed Mar 16 20:26:03 PDT 2022

Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple)

MoneyGram, which has about 227,000 global money transfer agent locations in
191 countries and territories, was recapitalized in 2008 (same year of
Bitcoin's whitepaper). Goldman Sachs acquired an equity interest of 63
percent in MoneyGram for about $710 million. Per the 2008 agreement,
MoneyGram also received $500 million in debt financing from Goldman
Sachs (Cordeiro
2011) <https://sciwheel.com/work/citation?ids=10952410&pre=&suf=&sa=0>.

Walmart is the only MoneyGram agent, for both the Global Funds Transfer and
Financial Paper Products segments, that accounts for more than 10% of
revenue. In 2020, Walmart accounted for 13% of total MoneyGram’s revenue
and 16% in 2019 and 2018. Goldman Sachs (Investor) has a Participation
Agreement with Walmart Inc. (Walmart) under which the Investor is obligated
to pay Walmart certain percentages of any accumulated cash payments
received by the Investor in excess of the Investor's original investment in
the Company (MONEYGRAM INTERNATIONAL INC 2021)
<https://sciwheel.com/work/citation?ids=10952491&pre=&suf=&sa=0>.

In 2016, Ripple received New York’s First NY-DFS BitLicense for an
Institutional Use Case of Digital Assets (Larsen 2016)
<https://sciwheel.com/work/citation?ids=10953308&pre=&suf=&sa=0>. Shortly
after being NY-DFS accredited, Ripple announced it was teaming up with
MoneyGram to test payments using Ripple’s xRP virtual currency. During this
time, Ripple was making headlines as the xRP digital currency had surged —
and fallen — dramatically (Browne 2018)
<https://sciwheel.com/work/citation?ids=10953324&pre=&suf=&sa=0>. Soon
after, Ripple announced a $50 million investment in MoneyGram snagging a
10% equity stake in the firm. Brad Garlinghouse, Ripple’s CEO, added that
his firm would support MoneyGram’s “further expansion” into the European
and Australian payment corridors (De 2019)
<https://sciwheel.com/work/citation?ids=10953333&pre=&suf=&sa=0>.

   -

   Connecting the dots, MoneyGram is now one of the most expensive transfer
   providers (Tierney 2019)
   <https://sciwheel.com/work/citation?ids=10953437&pre=&suf=&sa=0> on planet
   Earth. Customers incur fees for postal mail, telephone calls, electronic
   mail, and other computerized messaging services.
   -

   Computer crimes as a threat is no less a threat because it is
   contingent, because the speaker does not intend or is unable to carry it
   out when the threat was not directly communicated to the MoneyGram customer
   as a target, or because the language used might be considered cryptic or
   ambiguously not part of the current New York BitLicense mandate.
   -

   Ripple simply made MoneyGram’s business more efficient, thus accruing
   more profits for Goldman Sachs directed out of Manhattan. From 2019 -
   2020, MoneyGram received more than $40 million in market development fees
   from Ripple Labs in return for providing liquidity to its On-Demand
   Liquidity (ODL) network. It can be calculated that 10%-15% of the proceeds
   came from Walmart customers, who are some of the most disenfranchised
   Americans financially.

Over the last five years, through conscious organizational HR
management, Goldman
Sachs created layer upon layer of New York BitLicense-related disguises and
cross-border systems under potential conspiracy and plausible deniability
to computer crimes and marketplace manipulation. Goldman Sachs' various
direct and/or indirect BitLicensee connections profit daily from virtual
currency market manipulation computer crimes with cross-border reach,
operating as a large syndicate group from lower Manhattan.

On Wed, Mar 16, 2022 at 6:30 PM Gunnar Larson <g at xny.io> wrote:

> *Great news out of the great state of New
> York: https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202203161
> <https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202203161>*
>
>
> *I am very proud of our Superintendent today. The other news of the day
> was not coordinated with this. Obviously, no collusion on soon to be
> bankrupt MoneyGram ...: *
>
> Superintendent of Financial Services Adrienne A. Harris announced today
> that MoneyGram International Inc. (“MoneyGram”) has agreed to pay $8.25
> million in penalties pursuant to a Consent Order entered into with the New
> York State Department of Financial Services (“DFS” or the “Department”).
> The Consent Order resolves the Department’s investigation into MoneyGram’s
> failure to adequately supervise local agents in New York City, including
> the Flushing neighborhood of Queens, that processed a substantial volume of
> suspicious transactions to China, in violation of Bank Secrecy
> Act/Anti-Money Laundering (“BSA/AML”) requirements and New York law.
>
> “Many New Yorkers depend on money transmitters to send money to their
> families, pay bills, and conduct other financial transactions,” said
> Superintendent Harris. “To maintain the integrity of that system for
> law-abiding New Yorkers, it is crucial money transmitters like MoneyGram
> diligently monitor all activity on its platform to prevent bad actors from
> abusing the system for illegal means.”
>
> An examination and subsequent enforcement investigation conducted by the
> Department found that MoneyGram did not adequately oversee the activity of
> six agents that saw a large spike in transaction volume of business with
> China from locations throughout New York City, including in Flushing,
> Queens.
>
>  In 2014, the year preceding the spike in transaction volume, for example,
> there were approximately 7,500 transactions between New York and China
> aggregating approximately $30,000,000; during the 17-month period from
> January 2016 through May 2017, however, there were more than 25,000
> transactions to China aggregating more than $100,000,000. The dramatic
> change in the number and size of the transactions processed by New York
> agents — most of which were small, store-front independent agents — was a
> clear indicator of increased money laundering risk, particularly given that
> the destination was known to carry a high AML risk. Moreover, other aspects
> of the increased transactions, including a suspicious pattern that many
> different senders transmitted money to the same recipient, were problematic
> and should have put MoneyGram on clear notice to address these risks.
>
> After being made aware of the suspicious spike in activity, MoneyGram
> terminated its relationship with the problematic agents and began
> instituting remedial measures designed to ensure better supervision of its
> agents across its network, among other measures. Under the settlement
> reached today, in addition to payment of a $8.25 million penalty, MoneyGram
> will be required to report to the Department on the enhancements to the
> policies and procedures of its BSA/AML compliance program, its Suspicious
> Activity Monitoring and Reporting program, and customer due diligence
> requirements. MoneyGram will also furnish data to the Department for
> ongoing monitoring purposes.
>
> DFS acknowledges MoneyGram’s cooperation with the investigation and its
> ongoing remedial efforts.
>
> Read a copy of the consent order on the DFS website.
> <https://www.dfs.ny.gov/industry_guidance/enforcement_discipline/ea20220315_moneygram>
>
> <https://www.dfs.ny.gov/industry_guidance/enforcement_discipline/ea20220315_moneygram>
> --
> *Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>*
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
> - Digital Currency
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
> - Entrepreneurship and Innovation (ip)
>
> G at xNY.io
> +1-646-454-9107
> New York, New York 10001
>

-- 
*Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>*
MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
- Entrepreneurship and Innovation (ip)

G at xNY.io
+1-646-454-9107
New York, New York 10001
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