OREANDA-NEWS. The Central Bank of Ireland (“the Central Bank”) fined Western Union Payment Services Ireland Limited (“WUPSIL” or “the Firm”) €1,750,000 and reprimanded it in relation to breaches of its obligations under Sections 54 and 55 of the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 (“the CJA 2010”).

The Central Bank found WUPSIL failed to demonstrate it had sufficiently robust policies and procedures for anti-money laundering and countering the financing of terrorism (“AML/CFT”) purposes.  In particular, the Central Bank identified deficiencies in WUPSIL’s Irish procedures on:

  1. AML/CFT outsourcing;
  2. Customer Due Diligence (“CDD”) record retention;
  3. induction and training of retail agents; and
  4. systems for monitoring and identifying suspicious activity

These findings have been accepted by WUPSIL as part of the settlement agreement between the Central Bank and WUPSIL.

The Central Bank’s Director of Enforcement, Derville Rowland said:

“The level of the €1,750,000 fine imposed reflects a significant increase to penalties imposed previously by the Central Bank for failures in respect of a firm’s anti-money laundering/countering the financing of  terrorism procedures.   

The Central Bank action must be viewed in light of the inherent risks in the sector in which this firm operates and by reference to the scale and geographic size of the firm’s business and its reliance on third party agents and outsourced service providers.

The Firm is a global market leader in the provision of payment services.  I am therefore concerned that this firm failed to have in place sufficiently robust systems and procedures to train agents, to monitor and identify suspicious activity in respect of smaller transactions, and to maintain appropriate records.

Where firms choose to engage in outsourcing or place reliance on third party agents, it is our clear expectation and requirement that they put in place appropriate outsourcing controls. I would further remind firms that the obligations imposed on firms and management apply equally in situations where activity is outsourced on an intra-group basis as it does to situations where activity is outsourced externally.”