Western Union 2013 Annual Report Download - page 150

2013 FORM 10-K
40
On March 20, 2012, the Company was served with a federal grand jury subpoena issued by the United States Attorney's Office
for the Central District of California ("USAO") seeking documents relating to Shen Zhou International ("US Shen Zhou"), a former
Western Union agent located in Monterey Park, California. The principal of US Shen Zhou was indicted in 2010 and in December
2013, pled guilty to one count of structuring international money transfers in violation of United States federal law in U.S. v. Zhi
He Wang (SA CR 10-196, C.D. Cal.). Concurrent with the government's service of the subpoena, the government notified the
Company that it is a target of an ongoing investigation into structuring and money laundering. Since March 20, 2012, the Company
has received additional subpoenas from the USAO seeking additional documents relating to US Shen Zhou, materials relating to
certain other former and current agents and other materials relating to the Company's anti-money laundering compliance policies
and procedures. The government has interviewed several current and former Western Union employees and has served grand jury
subpoenas seeking testimony from several current and former employees. The government's investigation is ongoing and the
Company may receive additional requests for information as part of the investigation. The Company continues to cooperate fully
with the government. The Company is unable to predict the outcome of the government's investigation, or the possible loss or
range of loss, if any, which could be associated with the resolution of any possible criminal charges or civil claims that may be
brought against the Company. Should such charges or claims be brought, the Company could face significant fines, damage awards
or regulatory consequences which could have a material adverse effect on the Company's business, financial condition and results
of operations.
The Company has had discussions with the United States Federal Trade Commission (the "FTC") regarding the Company's
consumer protection and anti-fraud programs. On December 12, 2012, the Company received a Civil Investigative Demand ("CID")
from the FTC requesting that the Company produce (i) all documents relating to communications with the monitor appointed
pursuant to the Settlement Agreement, including information the Company provided to the monitor and any reports prepared by
the monitor, and (ii) all documents relating to complaints made to the Company by consumers anywhere in the world relating to
fraud-induced money transfers since January 1, 2011. On April 15, 2013, the FTC filed a petition in the United States District
Court for the Southern District of New York requesting an order to compel production of the requested documents. On June 6,
2013, the Court granted in part and denied in part the FTC's request. On August 14, 2013, the FTC filed a notice of appeal. On
August 27, 2013, Western Union filed a notice of cross-appeal. On February 21, 2014, the Company received another CID from
the FTC requesting the production of all documents relating to complaints made to the Company by or on behalf of consumers
relating to fraud-induced money transfers that were sent from or received in the United States since January 1, 2004, except for
documents that were already produced to the FTC in response to the first CID. The Company is unable to predict the outcome of
this matter, or provide a range of loss, if any, which could be associated with any possible claims that might be brought against
the Company.
On November 25, 2013, the Company was served with a federal grand jury subpoena issued by the United States Attorney’s
Office for the Middle District of Pennsylvania (“USAO-MDPA”) seeking documents relating to complaints made to the Company
by consumers anywhere in the world relating to fraud-induced money transfers since January 1, 2008. Concurrent with the
government's service of the subpoena, the government notified the Company that it is the subject of the investigation. Since
November 25, 2013, the Company has received additional subpoenas from the USAO-MDPA seeking documents relating to certain
Western Union agents and Western Union’s agent suspension and termination policies. The government's investigation is ongoing
and the Company may receive additional requests for information as part of the investigation. The Company is cooperating fully
with the government. The Company is unable to predict the outcome of the government's investigation, or the possible loss or
range of loss, if any, which could be associated with the resolution of any possible criminal charges or civil claims that may be
brought against the Company. Should such charges or claims be brought, the Company could face significant fines, damage awards
or regulatory consequences which could have a material adverse effect on the Company's business, financial condition and results
of operations.
We regularly receive subpoenas and other requests for documents and information from governmental authorities (federal,
state, local, and foreign) concerning our current or former agents, customers or other third parties. We cooperate with such subpoenas
and requests in the ordinary course of our business. However, it is possible that, during the course of any investigation or review
by such governmental authorities, allegations of misconduct or wrongdoing could arise regarding Western Union, its employees,
or agents, which could lead to investigations or enforcement actions against us.