A money services business agreed to pay $401,697 to settle its potential civil liability for apparent violations of the Global Terrorism Sanctions Regulations.
According to OFAC, between December 9, 2010 and March 13, 2015, Western Union Financial Services, Inc. ("Western Union") was connected through one of its principal master agents to the sub-agent Kairaba Shopping Center ("KSC"), a designated entity. During this time, Western Union processed over four thousand transactions, totaling approximately $1.275 million, for third-party, non-designated beneficiaries who collected their remittance at KSC.
Although Western Union had a process in place for screening master agents and related sub-agents, it did not filter location data for sanctions-related issues. Western Union eventually became aware of its association to KSC in February 2015 but, according to OFAC, mistakenly believed its sole location was no longer active. When it identified a second, active KSC location, Western Union suspended its relationship with KSC.
As part of its settlement agreement, Western Union agreed to "implemen[t] robust compliance procedures," which includes, among others, conducting regular risk assessments, ensuring that "internal controls appropriately mitigate its sanctions-related risks," conducting regular audits, and providing sanctions compliance training.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
