FTC Advisory Opinion Supports Money Transmitters’ Proposed Information Exchange


On September 4, the FTC’s Bureau of Competition issued an advisory opinion responding to a national money transmitters’ trade association inquiry about its planned information exchange regarding terminated U.S. money transmitter agents. According to the opinion, (i) the database will contain information regarding former U.S. sending and receiving agents whose contractual relationships were terminated due to failure to comply with federal and/or state law, or money transmitter contract terms or policies, (ii) exchange membership will be open to all licensed non-bank money transmitters, and (iii) participation in the information exchange will be voluntary, and each member of the information exchange will retain the right to decide unilaterally whether to appoint an agent that has been terminated by another exchange member. The FTC staff determined that the program (i) appears unlikely to harm competition, (ii) will contain several safeguards to lessen the risk of harm to competition and consumers, such as the appointment of a third-party vendor to maintain and secure the information exchange database, and (iii) is likely to improve the money transmitters’ ability to comply with federal and state laws designed to prevent money laundering, terrorist financing, and other criminal behavior, and enhance consumer welfare by preventing the appointment of fraudulent or criminal money transmitter agents.

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