Civil Enforcement Information - Western Union Financial Services, Inc.

Date issued: Jun. 07 2019

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (943 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...