Civil Enforcement Information - Western Union Financial Services, Inc.

Date issued: Jun. 07 2019

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TURBOFAC Commentary (926 words)

Notes:

1) LEGAL BASIS FOR LIABILITY

OFAC does not clearly connect the dots between facts and legal bases for liability. Some facts mentioned are essential for the egregiousness and other enforcement guidelines-related determinations, but not basic legal liability.

OFAC refers to a "master agent" and "sub-agent" relationship. It is described as follows in Western Union's SEC filings.

"In some countries outside the U.S., Western Union may operate through master agents, which are generally independent businesses that in turn subcontract with generally small independent stores who offer Western Union services at their locations. All Western Union Agent locations have access to the Money Transfer System and must send all Western Union transfers by wire via the Money Transfer System." [1] https://sec.report/Document/0001206774-17-000170/

With this setup, it is possible that OFAC would have held...