MSB - Western Union Question

We generally don't bank MSB's but got one by default (loan customer). They are an agent for Western Union doing wires and selling money orders.

We asked whether they have a process in place for independent review of their program and they indicated that Western Union will audit them, but they haven't come in yet (it's been over a year). We are unable to confirm whether WU is handing the independent review function as they won't return calls, etc. I just wondered if other Banks with Western Union customers could confirm whether Western Union handles the independent review function or are the agents responsible for handling that?

Thanks,

You might PM Dip. I think she works for Western Union now. I know she does on-site reviews of agents in her area.

I'm interested in seeing what kind of responses you get. We're dealing with a similar situation and just kind of stumbled onto regular debits from Western Union for one of our customers.

Western Union has paid fines on 1 or 2 occasions for AML deficiencies by it's agents.

I'm sure they are on their way to paying many more fines, judging by how rampant people are using Western Union to defraud people of money on many internet and social media sites. Just go to Instagram and search for the hashtag #flipmoney and see how many people are openly bragging about being Western Union agents that can help process cash transfers on behalf of other scammers, for a fee (that is most likely higher than and on top of whatever fee Western Union actually charges). These people are have no fear of being caught whatsoever.