MoneyGram entered into a deferred prosecution agreement in 2012 in exchange for full cooperation with the Department of Justice. It has taken some time for the DOJ to gather the information it needs to assess liability. In this particular case, due to the extreme nature of non-compliance, the potential penalty for failure to comply is a direct result of the harsh penalty structure dictated by the BSA. While as Compliance Chief, Mr. Hader should be held to some responsibility, the potential penalties (multi-million dollar) that could be assessed against Mr. Hader should give us pause, as this seems like a potential violation of the eighth amendment – excessive fines. The IRS needs to develop a bright-line and substantial thought-out regulations in regards to BSA compliance.