Disclaimer: This article provides educational information about Walmart’s anti-money laundering training requirements based on FTC settlement documents and federal regulations. It does not provide actual test questions or answers but explains the compliance concepts employees must understand.
Walmart associates working money transfer desks face a pass-or-fail computer test that allows zero room for error. The stakes climbed higher last June when federal regulators hit the retail giant with a $10 million penalty for letting scammers drain hundreds of millions from consumers between 2013 and 2018.
The anti-money laundering training at Walmart now carries weight that extends beyond employee onboarding. Every associate handling MoneyGram, Western Union, or Ria transactions must complete the computer-based learning module and answer every question correctly. Miss one, retake the entire test.
This requirement stems from the Bank Secrecy Act, which treats Walmart as a money services business at its 4,700 locations offering wire transfers. Federal law doesn’t suggest training. It mandates it.
Table of Contents
What the Computer-Based Learning Module Teaches
The CBL takes 20 to 30 minutes. Associates watch instructional videos covering customer verification, transaction monitoring, and fraud detection. Then comes the quiz, scenario-based questions that mirror situations employees encounter at service counters.
Customer Service associates and MoneyCenter staff must complete this training because they process money orders, wire transfers, and cash transactions daily. The curriculum covers Know Your Customer procedures, suspicious activity recognition, and federal reporting requirements.
Walmart operates money transfer services through partnerships with three major providers. When the Federal Trade Commission filed its complaint in June 2022, the agency alleged the company failed to train employees properly and neglected to warn customers about fraud risks.
Three Dollar Amounts That Trigger Federal Requirements
Money laundering prevention pivots on specific thresholds written into federal regulations:
$3,000 in cash for money orders or transfers requires identification. Associates must verify and record the customer’s name, address, and ID details. Walking away from the counter without collecting this information violates federal recordkeeping rules.
$10,000 in currency transactions triggers a Currency Transaction Report filing with the Financial Crimes Enforcement Network. This applies whether the amount comes from one transaction or multiple transactions in a single day by the same person.
$2,000 marks the floor for Suspicious Activity Reports when something about the transaction doesn’t add up. Money services businesses report at this lower threshold compared to banks, which use $5,000.
Breaking large sums into smaller transactions to dodge the $10,000 reporting requirement is called structuring. Federal law makes this a crime carrying up to five years in prison, regardless of whether the underlying money is legal or illegal.
Fraud Schemes That Cost Consumers Millions
The training walks employees through scams that repeatedly hit wire transfer services:
Grandparent scams involve calls from someone claiming to be a relative in jail, hospitalized, or stranded abroad. The caller begs for immediate money and secrecy. Sometimes a second caller poses as a lawyer or police officer to add credibility.
Lottery fraud starts with news about winning a foreign lottery or sweepstakes the victim never entered. Before claiming the prize, they must wire payment for taxes or processing fees. No legitimate lottery requires upfront payment.
Government impersonation tactics use IRS, Social Security Administration, or law enforcement identities. Scammers threaten arrest, deportation, or license suspension unless the victim wires money immediately or loads gift cards.
Romance scams develop over weeks or months online before the scammer manufactures an emergency requiring money. The request comes after trust is established through regular communication.
Christopher Mufarrige, who directs the FTC’s Bureau of Consumer Protection, explained in the June 2025 settlement announcement why these services attract scammers: “Electronic money transfers are one of the most common ways that scammers tell consumers to send them money, because once it’s sent, it’s gone for good.”
Warning Signs at the Service Counter
Associates learn to watch for behavioral and transactional patterns that signal potential fraud or money laundering:
- Multiple money orders purchased just below $3,000 to avoid showing identification
- Same customer returning several times in one day for separate transactions
- Customer appears nervous, confused, or unable to explain the transfer purpose
- Elderly person accompanied by someone who does most of the talking
- Large gift card purchases paid entirely in cash
- Refusal or inability to provide required identification when threshold is met
- Wire transfers to high-risk countries with no clear business or family connection
- Customer admits visiting other Walmart locations the same day
The training emphasizes that criminals use “smurfing” to move dirty money through the financial system. They recruit multiple people to make small deposits or transfers that individually stay below reporting thresholds but collectively move large sums.
What Happens When Employees Spot Something Wrong
Associates who identify suspicious transactions must escalate to store management and the compliance team. The key rule: never tip off the customer that a report is being filed.
Suspicious Activity Reports go directly to FinCEN, the Treasury Department bureau overseeing the Bank Secrecy Act. Federal law protects employees from retaliation for filing SARs and prohibits telling customers about the reports.
The June 2025 settlement order requires Walmart to implement monitoring systems flagging potentially fraudulent transactions. The company cannot process transfers it knows or consciously avoids knowing are fraud related.
Walmart is also barred from helping telemarketers who accept cash-to-cash transfers for goods, services, or charitable contributions, or who request advance payments for loans or credit.
The Federal Case That Changed Training Requirements
The FTC’s June 2022 complaint targeted Walmart’s money transfer operations between 2013 and 2018. Regulators alleged the company allowed its services to be used by scammers who defrauded consumers out of hundreds of millions.
According to the complaint, Walmart failed to implement effective anti-fraud policies, did not train employees adequately, and neglected to warn customers about potential fraud related to money transfers.
The agency filed an amended complaint in June 2023 adding telemarketing violations. A federal district court in Illinois dismissed those claims twice, in March 2024 and again in July 2024. In November 2024, the Seventh Circuit Court of Appeals granted Walmart permission to appeal other district court rulings.
Walmart defended its program throughout the litigation. The company stated in June 2022 that associates “stopped hundreds of millions of dollars in suspicious transactions” and that it maintains a comprehensive anti-fraud program.
The settlement resolved the case in June 2025 with Walmart paying $10 million but not admitting wrongdoing. The company agreed to continue its fraud prevention program and implement additional monitoring measures.
Consequences for Violations Extend Beyond the Company
Individual employees face legal exposure for willful violations of anti-money laundering laws. Criminal penalties include substantial fines and potential prison time for associates who knowingly help money laundering activities.
For consumers, the cost is permanent. Wire transfers and money orders offer no chargeback protection. Once money leaves through these services, recovery is nearly impossible.
Financial institutions that fail Bank Secrecy Act compliance face steep penalties. Major banks have paid billions in fines for anti-money laundering program failures in recent years.
The three-member FTC Commission voted 3-0 to approve the settlement order, which was filed in the U.S. District Court for the Northern District of Illinois.
Training Requirements Continue After the Initial Test
Federal regulations require ongoing education for money services business employees, not just one-time training during onboarding. As fraud schemes change and regulations get updated, associates receive new training modules.
The 100% passing requirement exists because the application demands precision. When a customer approaches the counter for a $3,500 wire transfer, the associate must know without hesitation that identification is required and must be recorded.
Associates who don’t pass can review materials and retake the assessment. Store managers answer questions and explain concepts. But there’s no margin for error on the final score because there’s no margin for error in real transactions.
The Computer-Based Learning program continues to serve as the first line of defense between scammers and consumers who use money transfer services. Eight months after the settlement, the training matters more than passing a test. It determines whether vulnerable customers walk away with their money or hand it to criminals.
