Enforcement
June 12, 2019

Western Union Settles Sanctions Probe Relating to Gambian Transactions

By Samuel Rubenfeld

 

Western Union Financial Services, Inc. agreed last Friday to settle a case of violations of counter-terorrism sanctions regulations involving a sanctioned entity based in The Gambia.

The Denver-based money services business processed nearly 5,000 remittance transactions totaling about $1.275 million between December 2010 and March 2015, paid out to third-party beneficiaries who collected their funds at Gambian supermarket Kairaba Shopping Center (KSC), which was sanctioned by the U.S. in 2010, according to the U.S. Treasury Department.

Western Union established a “master agent” relationship with an unnamed bank, which enlisted KSC as a sub-agent in 2006, years before KSC was sanctioned, according to the Treasury. Western Union, however, had treated KSC as an agent location of the bank, rather than a discrete entity acting as a sub-agent. Failures in its sanctions screening process led Western Union to miss the nature of the relationship, according to the enforcement notice.

Western Union told The Wall Street Journal’s Morning Risk Report that it had made substantial investments and enhancements to its sanctions compliance program.

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