Similarly, Western Union has failed to stop or discipline agents who repeatedly violate BSA and Western Union policies through their structuring activities in the Central District of California and the Eastern District of Pennsylvania. The BSA requires financial institutions, including financial service providers such as Western Union, to report on monetary transactions (CTRs) for currency transactions in excess of $10,000 in a single day. To avoid the submission of a CTR and identification requirement, criminals often structure their monetary transactions so that no transaction exceeds the $10,000 threshold. Financial institutions are required to report the alleged structuring if the total number of transactions made by or on behalf of an individual exceeds $10,000 in a business day. Western Union knew that some of its U.S. agents allowed or supported and supported the structuring of their customers. Instead of taking corrective action to eliminate structuring at and through its agents, Western Union has allowed agents to continue to send transactions through the Western Union system and to pay bonuses for paid agents. Despite repeated compliance checks that revealed the suspicious or illegal behaviour of its officers, Western Union almost never identified the suspicious activity that these officers were causing in their necessary reports to law enforcement. Our investigation revealed hundreds of millions of dollars sent to China in structured transactions to circumvent the reporting obligations of the Secrecy Bank Act, and much of the money was sent to China by illegal immigrants to pay their human traffickers. “,” said U.S. Attorney Decker. In one case that is being followed by my office, a western Union representative pleaded guilty to structured transactions by the federal government, an illegal conduct that the company had known about for at least five years.
Western Union documents show that its employees, because of the magnitude of their work, fought for this agent – as well as several independent agents in New York – to work for Western Union. Today`s measure will enable the Western Union to effectively control its agents and prevent the use of its money transfer system for illegal purposes. In a related case, Western Union agreed to settle the FTC`s charges in a complaint filed today with the U.S. District Court for the Middle District of Pennsylvania, claiming that the company`s conduct was contrary to the FTC Act. The complaint accuses fraudsters around the world of using Western Union`s money transfer system, while the company has long been aware of the problem, and some Western Union agents were complicit in fraud. The FTC complaint argues that Western Union refused to adopt effective anti-fraud measures and procedures and did not immediately take action against officers in difficulty. Western Union identified many problem agents, but took advantage of its actions by not suspending them and terminating them immediately. According to the confessions contained in the Deferred Prosecution Agreement (DPA) and the accompanying facts, Western Union violated the U.S. law – the Bank Secrecy Act (BSA) and the Anti-Fraud Act – between 2004 and 2012, by making hundreds of thousands of transactions for Western Union agents and others who participated in an international consumer fraud scheme.