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On June 22, 2026, the Texas Department of Banking announced that it and the Colorado Division of Banking entered into a joint consent order with a licensed money transmitter concerning alleged deficiencies in the company's anti-money laundering and countering the financing of terrorism (AML/CFT) compliance program. According to the consent order, the examination identified alleged violations of the federal Bank Secrecy Act's implementing regulations, the FTC Safeguards Rule, and state money transmission laws.
The consent order stems from a multistate examination initiated in May 2025. The examination allegedly identified issues involving the company’s AML/CFT program, including regulatory reporting, agent monitoring, independent reviews, and customer-information safeguards. Specifically, the consent order alleges:
- Late federal reporting. Required currency transaction reports and reports of transportation of currency or monetary instruments allegedly were not filed on time under FinCEN regulations.
- Agent-monitoring weaknesses. Domestic-agent oversight allegedly was not sufficiently implemented as part of the AML/CFT program.
- Independent-review deficiencies. Prior examination findings and a prior independent review allegedly had not been adequately addressed through periodic testing of the AML/CFT program.
- Customer-information safeguards. Device and software-system inventories were not adequately identified and managed under the FTC Safeguards Rule.
Without admitting the allegations, the company agreed to pay a $200,000 administrative penalty, divided equally between Texas and Colorado. The company also agreed to retain an independent compliance consultant, enhance its AML/CFT program and monitoring systems, strengthen customer due diligence and data-integrity controls, and submit quarterly progress reports for up to two years.
Putting It Into Practice: State regulators continue to coordinate multistate examinations and enforcement actions involving money transmitters (previously discussed here). Money transmitters should review their AML/CFT programs, transaction monitoring systems, vendor oversight, and regulatory reporting processes to ensure they satisfy both federal requirements and state supervisory expectations.
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