Western Union OFAC Settlement: $401.7K (2019)

Between December 9, 2010, and March 13, 2015, a bank in The Gambia was one of Western Union's principal Master Agents in The Gambia. In or around 2006, the bank had established a Sub-Agent relationship with Kairaba Shopping Center (KSC), an entity subsequently designated by OFAC pursuant to the Global Terrorism Sanctions Regulations (GTSR) on December 9, 2010. Western Union stored KSC's information in its systems as an agent location of the bank, and not as a discrete legal entity acting as a sub-agent.

During the review period, Western Union had a process to screen Master Agents and related sub-agents, and conducted real-time transaction screening of remitters and beneficiaries. However, for the majority of the review period, Western Union did not screen location data for sanctions-related issues as part of its review process.

Western Union became aware that KSC was a potential sub-agent in early February 2015, but mistakenly believed at that time that KSC had operated from a single location, which was no longer active as of that date. On March 25, 2015, Western Union identified a second, active KSC location and immediately suspended its relationship with KSC and deactivated its access to the Western Union network.

Between December 9, 2010, and March 13, 2015, Western Union processed 4,977 transactions totaling approximately $1.275 million, which were paid out to third-party, non-designated beneficiaries who chose to collect their remittances at KSC. OFAC determined that Western Union processed transactions involving a Specially Designated National (SDN) for more than four years following the entity's designation by OFAC, and that after Western Union discovered that this Sub-Agent was an SDN, failed to deactivate KSC's access to the Western Union network immediately due to its mistaken belief that the Sub-Agent was already inactive.

OFAC determined that Western Union voluntarily self-disclosed the apparent violations, and that the apparent violations constitute a non-egregious case. The statutory maximum civil monetary penalty amount was $1,244,250,000, and the base civil monetary penalty amount was $637,614. The settlement amount of $401,697 reflects OFAC's consideration of the applicable facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Starting in 2013, two years prior to discovering the apparent violations, Western Union began a project to remediate the root cause of the apparent violations. As part of its settlement with OFAC, Western Union agreed to sustain its commitment to implementing robust compliance procedures by ensuring that it continues to have a management team in place that: (1) is committed to a culture of compliance; (2) conducts regular risk assessments; (3) ensures that its internal controls appropriately mitigate its sanctions-related risks; (4) conducts regular audits; and (5) provides ongoing sanctions compliance training throughout the organization.

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