Western Union 2011 Annual Report Download - page 24

United States. These rules have resulted in increased compliance costs and may lead to increased competition in
our areas of service. Additional countries may adopt legislation similar to these laws. The PSD, as well as
legislation in other countries such as Russia, has also allowed an increased number of non-bank entities to
become money transfer agents.
We have developed and continue to enhance global compliance programs to monitor and to address various
legal and regulatory requirements. Our money transfer network operates through third-party agents in most
countries, and our legal and practical ability to control those agents’ compliance activities is limited. To assist in
managing and monitoring money laundering and terrorist financing risks, we have developed and continue to
enhance our global compliance programs, including an anti-money laundering compliance program, which
comprises policies, procedures, systems and internal controls. We have employees in a number of our offices
around the world dedicated to our global compliance program efforts. In connection with an agreement and
settlement with the State of Arizona and other states entered into in February 2010, we have funded $71 million,
a portion of which was paid to a not-for-profit organization to promote safety and security along the entire United
States and Mexico border, with the rest paid to the State of Arizona for its costs associated with this matter. This
agreement and settlement also resolved all outstanding legal issues and claims with the State of Arizona. In
addition, as part of the agreement and settlement, we have made and expect to make certain investments in our
compliance programs along the United States and Mexico border and a monitor has been engaged for those
programs. The costs of the investments in our programs and for the monitor are expected to reach up to
$23 million over the period from signing to 2013. See also Item 1A, Risk Factors—“Western Union is the
subject of governmental investigations and consent agreements with or enforcement actions by regulators” for
more information on this agreement and settlement, including the potential impact on our business.
Government agencies both inside and outside the United States may impose new or additional rules on money
transfers affecting us or our agents or their subagents, including regulations that:
• prohibit transactions in, to or from certain countries, governments and individuals and entities;
• impose additional identification, reporting or recordkeeping requirements;
• limit the types of entities capable of providing money transfer services or impose additional licensing or
registration requirements;
• impose minimum capital or other financial requirements on us or our agents and their subagents;
• limit or restrict the revenue which may be generated from money transfers, including transaction fees and
revenue derived from foreign exchange;
• require enhanced disclosures to our money transfer customers;
• require the principal amount of money transfers originated in a country to be invested in that country or
held in trust until they are paid;
• limit the number or principal amount of money transfers which may be sent to or from the jurisdiction,
whether by an individual, through one agent or in aggregate; or
• impose taxes or fees on money transfer transactions.
Unclaimed Property Regulations
Our Company is subject to unclaimed property laws in the United States and abroad. These laws require us to
turn over to certain government authorities the property of others held by our Company that has been unclaimed
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