MoneyGram Payment Systems, Inc. OFAC Settlement: $34.3K

Last updated: July 20, 2026

MoneyGram Payment Systems, Inc., a global payments company that allows people to send money in more than 200 countries and territories, settled its potential civil liability for 359 apparent violations of multiple sanctions programs for $34,328.78. MoneyGram provided services to blocked individuals incarcerated in U.S. federal prisons without a license from OFAC, processed transactions on behalf of an additional blocked person, and processed transactions for individuals who initiated commercial transactions involving Syria. The apparent violations involved the Foreign Narcotics Kingpin Sanctions Regulations, the Narcotics Trafficking Sanctions Regulations, the Syrian Sanctions Regulations, the Democratic Republic of the Congo Sanctions Regulations, the Central African Republic Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. OFAC determined that the apparent violations were voluntarily self-disclosed and were non-egregious.

Penalty Amount

$34,328.78

Enforcement Date

April 29, 2021

Rank in Top Penalties

#338

Case Details

Type:: Entity
Name:: MoneyGram Payment Systems, Inc.
Country:: 🇺🇸 United States
Industry:: Payments
Address:: Dallas, Texas
Penalty amount:: $34,328.78
Base civil monetary penalty:: $52,813.50
Max civil monetary penalty:: $302,938,437.00
Egregious case:: No
Apparent violations:: 359
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: March 12, 2013 to June 21, 2020
Program:: Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R §598.203Narcotics Trafficking Sanctions Regulations, 31 C.F.R. §536.201Syrian Sanctions Regulations, 31 C.F.R. §542.207Democratic Republic of the Congo Sanctions Regulations, 31 C.F.R. §547.201Central African Republic Sanctions Regulations, 31 C.F.R. §553.201Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. §544.201
Enforcement date:: April 29, 2021

Nature of the Apparent Violations

Between March 2013 and April 2016, MoneyGram provided money transfer services to the Department of Justice's Federal Bureau of Prisons (BOP), which allowed inmates to send and receive funds into and out of their personal commissary accounts. Between March 2013 and January 2015, MoneyGram did not screen the inmates against the SDN List. MoneyGram knew that some of the inmates for whom it was processing transactions could be on the SDN List, but it erroneously believed that such screening of inmates in federal prison was not expected under the BOP program. MoneyGram identified the issue as part of a compliance improvement program.

Once MoneyGram began screening these transactions, it nonetheless continued to process transactions on behalf of blocked persons in federal prisons due to other screening, technology, and fuzzy logic failures, as well as limited instances of human error. Similar screening and technology failures also led MoneyGram to process a limited number of transactions for an additional blocked person. In addition, MoneyGram processed commercial transactions related to Syria due to human error, when MoneyGram analysts improperly determined that commercial transactions qualified as non-commercial, personal remittances.

In total, between March 12, 2013 and June 21, 2020, MoneyGram processed 359 transactions totaling $105,627 on behalf of approximately 40 individuals on the SDN List, as well as for two individuals who initiated commercial transactions involving Syria. This conduct resulted in apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. §598.203; the Narcotics Trafficking Sanctions Regulations, 31 C.F.R. §536.201; the Syrian Sanctions Regulations, 31 C.F.R. §542.207; the Democratic Republic of the Congo Sanctions Regulations, 31 C.F.R. §547.201; the Central African Republic Sanctions Regulations, 31 C.F.R. §553.201; and the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. §544.201.

How OFAC Determined the Penalty

The statutory maximum civil monetary penalty applicable in this matter is $302,938,437. OFAC determined that MoneyGram voluntarily self-disclosed the apparent violations and that the apparent violations constitute a non-egregious case. Accordingly, under OFAC's Economic Sanctions Enforcement Guidelines, the base civil monetary penalty amount is $52,813.50. The settlement amount of $34,328.78 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

Aggravating Factors

MoneyGram knew that there could be incarcerated blocked persons that would be receiving payments into their commissary accounts, but did not screen the beneficiaries of the transactions against the SDN List because of an erroneous misunderstanding of its obligations
MoneyGram is a large and commercially sophisticated international financial institution

Mitigating Factors

The majority of the transactions were destined for blocked persons in custody in the United States and would likely have been eligible for a license
MoneyGram has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the Apparent Violations
MoneyGram cooperated with OFAC's investigation into these Apparent Violations
MoneyGram discovered the Apparent Violations as part of its ongoing efforts to improve its compliance program and voluntarily self-disclosed the Apparent Violations; MoneyGram represented that it has taken strong remedial action, including: retiring its legacy screening system and launching a new system that contains substantially more features to screen, monitor, and resolve sanctions and other compliance-related alerts; implementing screening for all BOP-related transactions and denying services to commissary accounts that belong to known blocked persons based on a daily batch screen of all inmates in federal prison; now requiring that the inmate name, rather than just the inmate account number, is included in the transaction data so that this information is caught during compliance screening; implementing additional training to its agent network to increase the quality of data collected by agents; and in 2016 increasing its Compliance Department by 128 employees, appointing a new Chief Compliance Officer, and significantly increasing its investment in compliance-related functions
As part of its agreement with OFAC, MoneyGram has undertaken to continue its implementation of these and other compliance commitments

Compliance Takeaways

This action highlights that money services businesses processing transactions for individuals worldwide — including individuals potentially ordinarily resident in, or doing business in, countries subject to U.S. sanctions — should understand the sanctions risks associated with those services and take steps necessary to mitigate those risks. This action also highlights the importance of maintaining robust sanctions screening software and processes, especially for U.S. companies that operate globally.

Official Source Documents

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.

View archived version View on ofac.treasury.gov

Archived on June 13, 2026

SHA-256: 28925c44282d02ec49c7b2fabf33f9f1ec2b8220af2a1c38870fb958eb5f918d