MoneyGram 2009 Annual Report Download - page 690

vendor it had authorized to pay money transfer receivers in Cuba may have paid some receivers in Cuban pesos. Upon learning of this possible
violation, MoneyGram voluntarily suspended its money transfer service to Cuba and began an investigation to determine whether a violation had
occurred. After extensive discussions with the vendor and a thorough internal investigation, MoneyGram was unable to determine with certainty
whether violations had occurred. Nonetheless, MoneyGram self-reported the possible violations. Since it self-reported, MoneyGram has been contacted
by OFAC for additional information and MoneyGram has fully cooperated with these requests. MoneyGram does not know what, if any, action OFAC
may take regarding this matter.
3. On July 24, 2007, the IRS issued a Letter 1112 to MoneyGram International, Inc., (MGI) listing several apparent violations of the Bank Secrecy Act
(BSA) that were discovered during the course of an ordinary BSA exam the IRS conducted on MGI's compliance program for the time period of
October 1, 2004 through December 31, 2004. MGI responded to the Letter 1112 on August 31, 2007 with detailed information regarding the apparent
violations. On February 22, 2008, the Department of the Treasury's Financial Crimes Enforcement Network sent a letter to MGI stating that the IRS
exam and Letter 1112 were now resolved by the issuance of the letter which it described as a warning letter.
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