Western Union 2015 Annual Report Download - page 149

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ITEM 3. LEGAL PROCEEDINGS
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 anti-money laundering
("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
has provided and continues to provide information and documents to the government. Due to the investigative stage of the matter
and the fact that no criminal charges or civil claims have been brought, the Company is unable to predict the outcome of the
government's investigation, or reasonably estimate the possible loss or range of loss, if any, which could be associated with the
resolution of any possible charges or 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, results of operations, and cash flows.
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's investigation is ongoing and the Company may receive additional requests for information as part
of the investigation. The Company has provided and continues to provide information and documents to the government. The
government has interviewed several current and former Western Union employees. Due to the investigative stage of the matter
and the fact that no criminal charges or civil claims have been brought, the Company is unable to predict the outcome of the
government's investigation, or reasonably estimate the possible loss or range of loss, if any, which could be associated with the
resolution of any possible charges or 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, results of operations, and cash flows.
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 has interviewed several
current and former employees and has served grand jury subpoenas seeking testimony from several current and former employees.
The government has indicated that it believes Western Union failed to timely terminate or suspend certain Western Union agents
who allegedly paid or forwarded thousands of fraud-induced transactions sent from the United States to various countries from
at least 2008 to 2012. The government's investigation is ongoing and the Company may receive additional requests for information
as part of the investigation. The Company has provided and continues to provide information and documents to the government.
Due to the investigative stage of the matter and the fact that no criminal charges or civil claims have been brought, the Company
is unable to predict the outcome of the government's investigation, or reasonably estimate the possible loss or range of loss, if any,
which could be associated with the resolution of any possible charges or 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, results of operations, and cash flows.
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