The 2009 order required MoneyGram to conduct timely fraud investigations of any agent location that has received two or more fraud complaints within 30 days; has fraud complaints totaling five percent or more of the location’s total monthly received transactions; or has displayed any unusual or suspicious money transfer activity. It also must terminate locations that may be complicit in fraud-induced money transfers.

The FTC alleges that MoneyGram was aware for years of the high levels of fraud and suspicious activities involving certain agents, giving as an example the company's failure to place any restrictions on one large chain agent until approximately mid-2013, even though the chain was the subject of more fraud complaints than any other MoneyGram agent worldwide.

"Some of the chain’s locations had fraud rates as high as fifty percent of the money transfer activity," says the FTC. "When it did take disciplinary action, MoneyGram focused on lower-volume, 'mom and pop' agents with high levels of fraud, while treating large chain agents differently"

The FTC also alleges that MoneyGram’s computerised monitoring system, aimed at blocking known fraudsters from using its service, malfunctioned for an 18-month period in 2015 and 2016. During that time, MoneyGram failed to block individuals that the company knew or should have known were using its service for fraud or to obtain fraud-induced money transfers.

“The FTC’s 2009 order required MoneyGram to protect consumers from fraud through its money transfer system, and today we are holding MoneyGram accountable for its failure to do so,” says FTC chairman Joe Simons. “MoneyGram’s alleged failure to implement key provisions of the order allowed scammers to continue to use its money transfer system to rip off consumers.”

Under the terms of the settlement, Moneygram has also agreed to block the money transfers of known fraudsters and provide refunds to fraud victims in circumstances where its agents fail to comply with applicable policies and procedures. It is also required to introduce enhanced due diligence, investigative, and disciplinary requirements.