Western Union 2014 Annual Report Download - page 248

2014 FORM 10-K
THE WESTERN UNION COMPANY
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (Continued)
110
United States Department of Justice Investigations
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-CDCA") 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-CDCA 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 AML 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 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.
In March 2012, the Company was served with a federal grand jury subpoena issued by the United States Attorney’s Office
for the Eastern District of Pennsylvania (“USAO-EDPA”) seeking documents relating to Hong Fai General Contractor Corp.
(formerly known as Yong General Construction) (“Hong Fai”), a former Western Union agent located in Philadelphia, Pennsylvania.
Since March 2012, the Company has received additional subpoenas from the USAO-EDPA seeking additional documents relating
to Hong Fai. The government has interviewed several current Western Union employees. 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 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.