Western Union 2014 Annual Report Download - page 180

2014 FORM 10-K
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Western Union is the subject of litigation, including purported class action litigation, which could result in material
settlements, fines or penalties.
As a company that provides global financial services primarily to consumers, we are subject to litigation, including purported
class action litigation, and regulatory actions alleging violations of consumer protection, anti-money laundering, securities laws
and other laws. We also are subject to claims asserted by consumers based on individual transactions. We may not be successful
in defending ourselves in these matters, and such failure may result in substantial fines, damages and expenses, revocation of
required licenses or other limitations on our ability to conduct business. Any of these outcomes could adversely affect our
business, financial condition and results of operations. Further, we believe increasingly strict legal and regulatory requirements
and increased regulatory investigations and enforcement are likely to continue to result in changes to our business, as well as
increased costs, supervision and examination for both ourselves and our agents and subagents. These developments in turn may
result in additional litigation or other actions. For more information please see Part I, Item 3, Legal Proceedings and Part II,
Item 8, Financial Statements and Supplementary Data, Note 5, "Commitments and Contingencies."
Current and proposed regulation addressing consumer privacy and data use and security could increase our costs of
operations, which could adversely affect our operations, results of operations and financial condition.
We are subject to requirements relating to privacy and data use and security under federal, state and foreign laws. For
example, the FTC has an on-going program of investigating the privacy practices of companies and has commenced enforcement
actions against many, resulting in multi-million dollar settlements and multi-year agreements governing the settling companies'
privacy practices. Furthermore, certain industry groups require us to adhere to privacy requirements in addition to federal, state
and foreign laws, and certain of our business relationships depend upon our compliance with these requirements. As the number
of countries enacting privacy and related laws increases and the scope of these laws and enforcement efforts expand, we will
increasingly become subject to new and varying requirements. Failure to comply with existing or future privacy and data use
and security laws, regulations, and requirements to which we are subject or could become subject, including by reason of
inadvertent disclosure of confidential information, could result in fines, sanctions, penalties or other adverse consequences and
loss of consumer confidence, which could materially adversely affect our results of operations, overall business and reputation.
In addition, in connection with regulatory requirements to assist in the prevention of money laundering and terrorist financing
and pursuant to legal obligations and authorizations, Western Union makes information available to certain United States federal,
state, and foreign government agencies when required by law. In recent years, Western Union has experienced increasing data
sharing requests by these agencies, particularly in connection with efforts to prevent terrorist financing or reduce the risk of
identity theft. During the same period, there has also been increased public attention to the corporate use and disclosure of
personal information, accompanied by legislation and regulations intended to strengthen data protection, information security
and consumer privacy. These regulatory goals - the prevention of money laundering, terrorist financing and identity theft and
the protection of the individual's right to privacy - may conflict, and the law in these areas is not consistent or settled. The legal,
political and business environments in these areas are rapidly changing, and subsequent legislation, regulation, litigation, court
rulings or other events could expose Western Union to increased program costs, liability and reputational damage.
We are subject to unclaimed property laws, and differences between the amounts we have accrued for unclaimed property
and amounts that are claimed by a state or foreign jurisdiction could have a significant impact on our results of operations
and cash flows.
We are subject to unclaimed property laws in the United States and abroad which require us to turn over to certain government
authorities the property of others held by us that has been unclaimed for a specified period of time, such as unpaid money
transfers. We have an ongoing program to help us comply with those laws. In addition, we are subject to audits with regard to
our escheatment practices. Any difference between the amounts we have accrued for unclaimed property and amounts that are
claimed by a state or foreign jurisdiction could have a significant impact on our results of operations and cash flows. See
"Unclaimed Property Regulations" for further discussion.