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Transworld Transmitting Corp., a licensed money transmitter, entered into a Settlement Agreement with the Superintendent of Banks on March 4, 2004 which includes the payment of a $15,000 fine.


State of New York Banking Department
New York, New York


In the Matter of  

TRANSWORLD  TRANSMITTING CORP.

A Transmitter of Money Licensed Pursuant To Article XIII-B of the New York Banking Law 

               (Respondent)

SETTLEMENT AGREEMENT

WHEREAS, Transworld Transmitting Corp. (“Transworld” or the “Licensee”), with corporate headquarters at 27 8th Street, Passaic, New Jersey 07055, was granted a license on February 28, 2003 to engage in business as a money transmitter pursuant to Article XIII-B of the New York Banking Law (the “Banking Law”) by the Superintendent of Banks (the “Superintendent”) of the New York State Banking Department (the “Banking Department”); and 

WHEREAS, in recognition of their common goals to ensure compliance with applicable federal and state laws, rules and regulations by the Licensee and to manage financial, operational, legal, reputational and compliance risk of the Licensee, the Banking Department and the Licensee have mutually agreed to enter into this Settlement Agreement (“Agreement”); and

WHEREAS, a Banking Department examination as of June 30, 2003 revealed that Transworld had failed to adopt and implement an anti-money laundering compliance program, as required by 31 U.S.C. Section 5318 (h) & 31 C.F.R. Part 103.125; and

WHEREAS, as a result of the findings of such examination, Licensee has voluntarily ceased operations; and

WHEREAS, the Superintendent and the Licensee mutually agree to resolve the issues noted during the examination on the basis of the terms and conditions set forth herein, which include the payment by Licensee of a fine in the amount of $15,000.00, in lieu of litigating such issues in a hearing seeking revocation of Transworld’s license.

NOW, THEREFORE IT IS HEREBY STIPULATED AND AGREED BY THE PARTIES HERETO AS FOLLOWS:

  1. Fully understanding the terms and conditions of this Agreement, Transworld   knowingly and voluntarily waives (1) its right to a hearing on the violation cited above, and (2) any and all rights of appeal relating to the settlement of this matter.

  2. Transworld will take all necessary steps to assure that it is in compliance, and remains in compliance, with all applicable laws, rules and regulations, and to provide the Department with monthly reports with respect to its progress in implementing an appropriate anti-money laundering program.

  3. Transworld agrees to conduct an audit of its anti-money laundering program, performed by an outside audit firm acceptable to the Department, within six  (6) months of the date of this agreement. And submit a copy of the audit to the Banking Department within 15 days from the completion of said audit.

  4. Transworld agrees to pay a fine in the amount of $15,000.00 to the Superintendent, and further, that it will not restart its operations until, such fine has been paid. Payment shall be made by electronic transfer, in immediately available funds, pursuant to transfer instructions received from the Banking Department. Failure to make timely payment shall result in the commencement of a hearing to revoke the Licensee’s license.

  5. All communications regarding this Agreement shall be sent to:

Paul J. Fazio
Deputy Superintendent of Banks
Licensed Financial Services Division
New York State Banking Department
One State Street
New York, New York 10004

Marc Moyal, President
Transworld Transmitting Corp.
27 8th Street
Passaic, New Jersey 07055       

  1. The provisions of this Agreement shall not bar, estop or otherwise prevent the Superintendent, or any state or federal agency or department, from taking any other action affecting the Licensee, any of its current or former officers, directors, employees, or insiders, or their successors or assigns with respect to any matter relating to this Settlement Agreement.

  2. No extension or waiver of the terms of this Agreement shall be binding on the Banking Department unless it is in writing and signed by the Superintendent. 

  3. Each provision of this Agreement shall remain effective and enforceable until stayed, modified, terminated or suspended in writing by the Superintendent.

  4. The effective date of this Agreement is the date on which it is executed by the Superintendent or her Deputy.

  5. The provisions of this Agreement are not confidential.

Agreed to and Accepted: 

Dated:_________________

By: ___________________________
Paul J. Fazio
Deputy Superintendent of Banks 
New York State Banking Department 

Dated:_________________

By: ___________________________
Marc Moyal
President
Transworld Transmitting Corp.