Western Union Payment Services Ireland Limited

Background: WUPSIL offers money remittance services (i.e money transfer services). WUPSIL is authorised by the Central Bank to provide its services in the European Economic Area as a payment institution. WUPSIL provides its services to consumers through a large network of agents. In simple terms, the agents accept money on behalf of WUPSIL which transfers it as requested for a fee. The Central Bank conducted inspections in respect of its Irish business during which concerns regarding WUPSIL’s anti-money laundering processes arose. Following further inspections and investigation, a number of the failings were identified as contraventions (i.e. breaches) of the CJA 2010 that called for enforcement action as set out below. 3 Breaches of sections 54(1) and (2) of the CJA 2010 In summary, Sections 54 (1) and (2) of the CJA 2010 require firms to adopt policies and procedures to prevent and detect the commission of money laundering and terrorist financing. The Central Bank found that the Firm failed to adopt sufficiently robust policies and procedures as outlined below: Outsourcing of Anti-Money Laundering/Countering the Financing of Terrorism Compliance Functions WUPSIL outsourced key AML/CFT compliance functions to another WUPSIL group entity located in Lithuania by way of a ‘chain’ outsourcing arrangement. Prior to 2012, the contractual arrangements with the Lithuanian entity did not include adequate performance standards or provide for adequate reporting to WUPSIL on performance. Nor did the arrangements require the entity to adhere to the Firm’s policies and all legal obligations applicable to the Firm’s remittance services (including the CJA).