Jenner & Block

Client Alert: Personal Liability for Compliance Officer in MoneyGram Settlement: Powerful Motivator or Chilling Deterrent?

On May 4, 2017, the US Attorney’s Office for the Southern District of New York (SDNY) and the Financial Crimes Enforcement Network (FinCEN) announced the settlement of civil claims brought under the Bank Secrecy Act (BSA) against the former Chief Compliance Officer of MoneyGram International, Inc. (MoneyGram), Thomas Haider, stemming from MoneyGram’s failure to implement and maintain an effective anti-money laundering (AML) program or to timely file suspicious activity reports (SARs). The settlement represented the resolution of the first-ever suit filed by the federal government against an individual compliance officer in the finance industry, and is likely to add fuel to increasing anxiety regarding the Department of Justice’s (DOJ) willingness to hold corporate executives liable for compliance failings.