Enforcement takeaways (according to the Consent Order allegations):
• NYDFS appears more inclined recently to act with other regulators under the auspices of the Conference of State Banking Supervisors and Money Transmitter Regulators Association. The action grew out of a multi-state investigation and subsequent Interim Cease and Desist Order filed by the agencies in March 2024.
• NYDFS took the action against Sigue Corporation it said, for “failing to fulfill its obligations to customers during its collapse in 2024. As its financial condition deteriorated, the company failed to complete multiple money orders and transmissions and to maintain adequate net worth and permissible investments to cover outstanding liabilities, both violations of state money transmission law.”
• The total civil monetary penalty assessed collectively by the regulators was only $1 million, which would be nullified if Sigue fully complies with the Consent Order. Under the final agreement, customers can file claims for full refunds.
• The former CEO of Sigue also agreed he shall not act as director, manager owner or control person of a regulated money transmitter without permission from such regulator.