Western Union 2015 Annual Report Download - page 150

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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. Further, the government recently served Western Union with a subpoena
calling for data relating to transactions sent and received by 43 Nicaraguan agents from October 1, 2008 to October 31, 2013 and
transactions sent from the United States to the Bahamas, Peru, Dominican Republic, and Haiti from September 1, 2013 to January
2, 2014 and certain documents relating to those agents. The government also advised the Company that it is investigating concerns
the Company was aware there were gaming transactions being sent to Panama, Nicaragua, Haiti, Philippines, Vietnam, the
Dominican Republic, Peru, and the Bahamas (in addition to Costa Rica) and that the Company failed to take proper steps to stop
the activity. The government has also notified the Company that it is a target of the investigation. The government has interviewed
several current and former Western Union employees. The government's investigation is ongoing and the Company may receive
additional requests for information or seizure warrants 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.
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 reasonably
estimate 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, results of operations, and cash flows.
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