One of our bank's branches completes Western Union wire transfers. I have the following 2 questions.
1. Does that make our bank an MSB?
2. Does anyone know if Western Union does an OFAC scan on the purchaser or beneficiary of the WU wires? I can't find it any material we have received from them and we (the bank) are not doing any OFAC scan.

Thanks to all BOLers for coming to work today and not going shopping!!!!(ha, ha).

link

Here's a site worth getting acquainted with. Should answers all your MSB questions.

If your branch is a WU agent, there should be contacts within WU to answer your OFAC question. BTW, I know the managers responsible for BSA/AML/OFAC at Western Union/First Data, and they are among the best in the business. I just can't fathom the challenges in administering a AML program in a setting with some 40,000 independent agents. Most of which use part-time help at odd-hours to initiate money transfers or sell money orders. Humbles me why it should be so hard then to keep a program on track in a bank with only a dozen or so branches!

We use WU and I do not know if they scan payees against the OFAC list. It is your responsibility to ensure that you are not transferring funds to someone on the OFAC list. The sender, your customer may be ok but if the payee is Osama B.L. then you are the one in trouble; presumably WU would catch this and is obligated to report the attempted transfer.

On a related note, does anyone have any link to the finding that just became final on the Western Union franchisee issue?

I found the filing, if anyone needs it, let me know. $8 million fine in the state of NY, ouch. Pertains to failure on Western Union's part to adequately monitor franchise operations so as to be able to identify suspicious activity over multiple operations.

Western Union does indeed scan against OFAC on all parties involved in the money transfers. If you contact your representative, they can get you the information you need.

I would say that even though WU performs the OFAC check, you must do so as well. You are a financial institution responsible for such things and should not rely on the third party,

Hi i would like to take up a franchisee in mumbai plz guide me on how to to this