A topic that has caught my attention recently is Western Union television advertisements seen in the Miami area. These advertisements promote Western Union services throughout 140 municipalities in Cuba. The Cuban Assets Control Regulations (CACR) allows authorized remittances as defined in CFR 515.314.

Considering Western Union’s BSA/AML compliance program history:

-Dec. 2002 $8million penalty violating BSA, Patriot, and New York Banking Laws.
-Mar. 2003 $3 million civil money penalty.
-Feb. 2010 Arizona Attorney General $94 million criminal investigation.
-2015 it appears Western Union remains under supervision of a Monitor and could face new penalties by Arizona Attorney General. Deadline October 31, 2015 implementation primary recommendations report.

My attention is directed concerning the “Due Diligence” process performed by Western Union. I am not aware of how Western Union recruits its agents, although I suspect the company would say it does the proper due diligence so that if there is a challenge it can claim to be unaware of any issues. It would be interesting to know how Western Union effectively performed due diligence on approximately 140 agent offices in Cuba in such short time since the implementation of the CACR.

Are you aware of any recent writing I could reference covering Money Services Business due diligence process on the selection of their agents?

Thank you

Miguel Pacheco