Tagged: agents

Distribution Chains and Sanctions Compliance (Part II of IV)

Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment.  Additionally, companies may maintain parallel sales activities in markets between their own sales staff and third-party distributors, agents, resellers and dealers.  It is interesting how certain industries have evolved and relied on different models for use of third parties with the intent of reaching customers in...

A Money Laundering Nightmare: Western Union Ponies Up $770 Million to Settle with DOJ, FTC and FinCEN

Earlier this year, in January 2017, Western Union entered into a Deferred Prosecution Agreement with the Justice Department and the FTC, and agreed to pay $586 in forfeiture to settle anti-money laundering and consumer fraud violations. At the same time, Western Union agreed to pay $184 million in civil monetary penalties for AML violations. The Western Union prosecution sends an important reminder to financial institutions,...