![]() Western Union and the State shall agree on the language of a press release regarding this Agreement. Western Union and the State agree that they will issue a joint public announcement regarding this Agreement after acceptance of this Agreement by the Maricopa County Superior Court (the Western Union accepts and acknowledges responsibility for its conduct as set forth in the Statement of Admitted Facts.ħ. Money laundering activities in the Southwest Border Area, and to reach a global resolution of all potential regulatory, civil, and criminal actions that could arise from conduct described in the Statement of Admitted Facts, Western Union and theĦ. To achieve their common goal of combating That management believes pose the greatest risks (e.g., the Southwest U.S. Risks for money laundering/terrorist financing by tailoring its own risk assessment, identifying both pervasive and Company-specific threats and vulnerabilities, and to manage its AML risk by dedicating extensive and skilled resources to those areas The Report concluded that Western Union has taken extensive steps to fully appreciate its specific ![]() The execution of this Agreement, Western Union requested from the State a global resolution of all potential regulatory, civil, and criminal actions that could arise from conduct described in the Statement of Admitted Facts, attached hereto asĮxhibit A and incorporated herein by this reference, and it also provided the State with a May 8, 2009 report by an independent consulting firm evaluating Western Unions current AMLĬompliance program and its planned enhancements of that program (Report). Potentially suspicious activity building a team of AML professionals screening, training, and monitoring its Agents producing AML policies and manuals and implementing compliance measures in certain high-risk geographical areas, including all ofĪrizona and the area within 200 miles north and south of the United States/Mexico border (the Southwest Border Area). In so doing, Western Union has dedicated substantial resources to, among other things: developing transaction monitoring systems to detect Western Union has developed and implemented a risk-based anti-money laundering (∺ML)Ĭompliance program that is designed to prevent, detect, and report potential money laundering activities. In some foreign countries, such as Mexico, Western Unions Agents enter into agreements with additional locations (sometimes referred to as subagents) entitling the subagents to offerģ. Western Union conducts its business through ∺gents, referred to as authorized delegates in Arizona. In Arizona, Western Union is licensed to do business as a money transmitter under the Arizona Transmitters of Money Act, A.R.S. Western Union offers money transfer and other payment services at overĥ0,000 agent locations in the United States and over 375,000 locations around the world. Western Union Financial Services, Inc., (Western Union) a corporation organized under the laws ofĬolorado, pursuant to authority granted by its Board of Directors, and the State of Arizona (State) hereby enter into this Settlement Agreement (∺greement).ġ.
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