Thomas E. Haider

$1M CMP Thomas E. Haider


The Financial Crimes Enforcement Network (FinCEN) on December 18, 2014, assessed a $1 million civil money penalty against Thomas E. Haider for willful violation of the Bank Secrecy Act (BSA) and implementing regulations. Haider was the Chief Compliance Officer and Senior Vice President of Government Affairs at MoneyGram International Inc. ("MoneyGram").


According to FinCEN's Order, Haider (1) willfully violated the requirement to implement and maintain an effective anti-money laundering program; and (2) willfully violated the requirement to report suspicious activity. As compliance officer, said FinCEN, Haider was responsible for ensuring that MoneyGram implemented and maintained an effective AML program and complied with its SAR-filing obligations. The Order indicates the following:

• Failure to Implement a Discipline Policy. Haider failed to ensure that MoneyGram implemented a policy for disciplining agents and outlets that MoneyGram personnel knew or suspected were involved in fraud and/or money laundering.
• Failure to Terminate Known High-Risk Agents/Outlets. Haider failed to ensure that MoneyGram terminated agents and outlets that MoneyGram personnel understood were involved in fraud and/or money laundering, including outlets that Haider himself was on notice posed an unreasonable risk of fraud and/or money laundering.
• Failure to File Timely SARs. Haider failed to ensure that MoneyGram fulfilled its obligation to file timely SARs, including because Haider maintained MoneyGram's AML program so that the individuals responsible for filing SARs were not provided with information possessed by MoneyGram's Fraud Department that should have resulted in the filing of SARs on specific agents or outlets.
• Failure to Conduct Effective Audits of Agents/Outlets. Haider failed to ensure that MoneyGram conducted effective audits of agents and outlets, including outlets that MoneyGram personnel knew or suspected were involved in fraud and/or money laundering.
• Failure to Conduct Adequate Due Diligence on Agents/Outlets. Haider failed to ensure that MoneyGram conducted adequate due diligence on prospective agents, or existing agents seeking to open additional outlets, which resulted in, among other things, MoneyGram (1) granting outlets to agents who had previously been terminated by other money transmission companies and (2) granting additional outlets to agents who MoneyGram personnel knew or suspected were involved in fraud and/or money laundering.

See also the 11/9/2012 entry for MoneyGram International, Inc.