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Western Union Financial Services, Inc.


Industry: Banking & Finance
Underlying Misconduct: Money Laundering, Wire Fraud
Matter Type: DOJ Criminal
Relevant Jurisdiction(s): United States District Court for the Middle District of Pennsylvania
Penalties: Forfeiture
Fine Amount: $586,000,000
Reporting Agencies: Department of Justice Money Laundering and Asset Recovery Section, Federal Trade Commission
Resolution Form: Deferred Prosecution Agreement
Agreement Date: January 19, 2017
Monitor Reference Term: Independent Compliance Auditor
Monitor Identity: Unknown
Monitorship Term: 3 Years
Monitor Selection Process:

The DOJ DPA incorporated into it the service of the Monitor as per an Agreement with the FTC. The FTC Agreement is attached as primary, while the DOJ and FinCen Agreements are supplemental (see below). Per Agreement, Host Organization was to submit 3 candidates to FTC, who would select.

Time to Propose Monitors: 30 days
Time to Engage Monitor: Not Specified
Time to First Report: 6 mos
Reporting Frequency: Annually
Monitor Required Qualifications:

Independent third party, not an employee of Host Organization or Reporting Agency.

Summary of Monitor's Scope:

Ensure compliance with Sections I - V of the Agreement (FTC Order).

Summary of Monitor's Activities:

Review, assess, and evaluate Host Organization's compliance with the Agreement. Is authorized to choose, engage, and employ attorneys, investigators, accountants, appraisers and other independent contractors and technical specialists as Monitor deems advisable or necessary. Shall have immediate, unfettered access to all information, documents, personnel and premises in the possession, custody or control of Host Organization or any Host Organization agent that the Monitor deems necessary to carrying out Monitor duties, provided that the Monitor shall make reasonable efforts to avoid imposing upon Host Organization undue costs and burdens. Please see FTC Order at Section VI (attached below).

Monitor's Restrictions:

None noted in Agreement.

Documents Uploaded: Western-Union-FTC-Order-20Jan2017.pdf
Other Relevant Information: Western-Union-FinCen-Consent-Order-17Jan2017.pdf