Western Union 2015 Annual Report Download - page 151

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The Company has had discussions with the United States Federal Trade Commission (the "FTC") regarding the Company's
consumer protection and anti-fraud programs. On December 12, 2012, the Company received a civil investigative demand from
the FTC requesting that the Company produce (i) all documents relating to communications with the monitor (the "Monitor")
appointed pursuant to the agreement and settlement (the "Southwest Border Agreement") Western Union Financial Services, Inc.
entered into with the State of Arizona on February 11, 2010, as amended, including information the Company provided to the
Monitor and any reports prepared by the Monitor; and (ii) all documents relating to complaints made to the Company by consumers
anywhere in the world relating to fraud-induced money transfers since January 1, 2011. On April 15, 2013, the FTC filed a petition
in the United States District Court for the Southern District of New York requesting an order to compel production of the requested
documents. On June 6, 2013, the Court granted in part and denied in part the FTC's request. On August 14, 2013, the FTC filed
a notice of appeal. On August 27, 2013, Western Union filed a notice of cross-appeal. On February 21, 2014, the Company received
another civil investigative demand from the FTC requesting the production of all documents relating to complaints made to the
Company by or on behalf of consumers relating to fraud-induced money transfers that were sent from or received in the United
States since January 1, 2004, except for documents that were already produced to the FTC in response to the first civil investigative
demand. On October 7, 2014, the United States Court of Appeals for the Second Circuit entered a summary order reversing in
part and vacating and remanding in part the June 6, 2013 order entered by the United States District Court for the Southern District
of New York. On October 22, 2014, the Company received another civil investigative demand issued by the FTC requesting
documents and information since January 1, 2004 relating to the Company’s consumer fraud program, its policies and procedures
governing agent termination, suspension, probation and reactivation, its efforts to comply with its 2005 agreement with 47 states
and the District of Columbia regarding consumer fraud prevention, and complaints made to the Company by or on behalf of
consumers concerning fraud-induced money transfers that were sent to or from the United States, excluding complaint-related
documents that were produced to the FTC in response to the earlier civil investigative demands. The civil investigative demand
also seeks various documents concerning approximately 720 agents, including documents relating to the transactions they sent
and paid and the Company’s investigations of and communications with them. On July 31, 2015, the Company received another
civil investigative demand requesting documents and information relating to the total number of agent and subagent locations in
13 countries annually since 2010, the average and median dollar values for money transfers sent anywhere in the world annually
since 2010, copies of the Company’s anti-fraud programs, know your agent policy, know your customer policy, representative
agent contracts, transaction data, background investigation documents and fraud complaints associated with four agents in Greece,
Peru and Mexico and consumer fraud reports not already produced to the FTC. The Company has responded to each of the civil
investigative demands it has received from the FTC. The Company may receive additional civil investigative demands from the
FTC, and discussions between the Company and the FTC are ongoing. Due to the investigative stage of the matter and the fact
that no 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 claims that may
be brought against the Company.
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