Western Union 2014 Annual Report Download - page 185

2014 FORM 10-K
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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.
On March 6, 2014, the Company was served with a federal grand jury subpoena issued by the United States Attorney’s Office
for the Southern District of Florida (“USAO-SDFL”) seeking a variety of AML compliance materials, including documents relating
to the Company’s AML, Bank Secrecy Act (“BSA”), Suspicious Activity Report (“SAR”) and Currency Transaction Report
procedures, transaction monitoring protocols, BSA and AML training programs and publications, AML compliance investigation
reports, compliance-related agent termination files, SARs, BSA audits, BSA and AML-related management reports and AML
compliance staffing levels. The subpoena also calls for Board meeting minutes and organization charts. The period covered by
the subpoena is January 1, 2007 to November 27, 2013. The Company has received additional subpoenas from the USAO-SDFL
and the Broward County, Florida Sheriff’s Office relating to the investigation, including a federal grand jury subpoena issued by
the USAO-SDFL on March 14, 2014, seeking information about 33 agent locations in Costa Rica such as ownership and operating
agreements, SARs and AML compliance and BSA filings for the period January 1, 2008 to November 27, 2013. Subsequently,
the USAO-SDFL served the Company with seizure warrants requiring the Company to seize all money transfers sent from the
United States to two agent locations located in Costa Rica for a 10-day period beginning in late March 2014. On July 8, 2014, the
government served a grand jury subpoena calling for records relating to transactions sent from the United States to Nicaragua and
Panama between September 1, 2013 and October 31, 2013. The government has also notified the Company that it is a target of
the investigation. The investigation is ongoing and the Company may receive additional requests for information or seizure warrants
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.
Other Governmental Investigations
Since 2011, Western Union has received civil investigative demands from certain state attorneys general who have initiated
an investigation into the adequacy of the Company's consumer protection efforts over the last several years. The civil investigative
demands seek information and documents relating to money transfers sent from the United States to certain countries, consumer
fraud complaints that the Company has received and the Company's procedures to help identify and prevent fraudulent
transfers. Due to the stage of the investigation, the Company is unable to predict the outcome of the investigation, or the possible
loss or range of loss, if any, which could be associated with any possible civil claims that might be brought by one or more of the
states. Should such claims be brought, the Company could face significant fines, damage awards, or regulatory consequences, or
compulsory changes in our business practices that could have a material adverse effect on our business, financial condition and
results of operations.