Western Union Deferred Prosecution Agreement

Western Union`s complaint reminds financial institutions, traditional banks and non-traditional financial services companies, casinos and cheque-payment companies that facilitating criminal activity through financial services carries significant risks to the financial operator. To protect themselves from enforcement action or regulatory control, financial institutions must implement robust compliance programs that are not left behind when the business attempts to generate substantial revenue from questionable activities. The complaint was filed in February 2017 following the announcement of a deferred law enforcement agreement (DPA) between Western Union and the U.S. Department of Justice. The data protection authority relied on the Western Union`s alleged failure to maintain an effective AML programme between 2004 and 2012 and to support and support fraud over the course of the thread. The DATA agency we have previously blogged on has accused Western Union of submitting suspicious activity reports (“SAR”) on the activities of its clients, but has not provided SARs regarding the actions of its own agents, who were probably complicit. The Federal Trade Commission and FinCEN`s data protection and civil enforcement authority have asked Western Union for a combined fine of $586 million. Western Union also turns a blind eye to a significant number of transactions in California and Pennsylvania by agents who have structured transactions to avoid submitting NTCs. Instead of correcting these activities, Western Union continued to authorize such a bypass in order to continue to generate significant revenues. According to the confessions contained in the Deferred Prosecution Agreement (DPA) and the accompanying facts, Western Union violated the U.S.

law – the Bank Secrecy Act (BSA) and the Anti-Fraud Act – between 2004 and 2012, by making hundreds of thousands of transactions for Western Union agents and others who participated in an international consumer fraud scheme. In 2017, Western Union reached a lawsuit agreement with the United States in which the company acknowledged that it was violating the bank`s law and that it supported and supported fraud over the course of the line. Western Union agreed to withhold a total of $586 million to compensate victims of fraudulent transactions that were knowingly processed by the company. Western Union`s complaint reminds financial institutions, traditional banks and non-traditional financial services companies, casinos and cheque payment companies that facilitating criminal activity by financial services carries significant risks to the financial operator.