GLOBAL AGENT COMPLIANCE PROGRAM MANUAL - ALNA · GLOBAL AGENT COMPLIANCE PROGRAM MANUAL AGENT...

GLOBAL AGENT COMPLIANCE PROGRAM MANUAL

AGENT REFERENCE

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Global Agent Compliance Program Manual 20172 WESTERN UNION © 2017 Western Union Holdings, Inc. All Rights Reserved. CONFIDENTIAL. Rev. 08/2017

ATTENTION AGENTS: IF YOU, YOUR AGENT COMPLIANCE OFFICER OR ANY AGENT EMPLOYEES OR SUB-AGENTS HAVE QUESTIONS ABOUT ANY OF THE INFORMATION IN THIS MANUAL, PLEASE CONTACT YOUR DESIGNATED WESTERN UNION COMPLIANCE REPRESENTATIVE.

The WESTERN UNION name, logo and related trademarks and service marks, owned by Western Union Holdings, Inc., are registered or used in the U.S. and many foreign countries. THE INFORMATION CONTAINED IN THIS MATERIAL IS CONFIDENTIAL AND PROPRIETARY TO WESTERN UNION. ANY USE, COPYING, OR REPRODUCTION OF THIS MATERIAL WITHOUT THE PRIOR WRITTEN PERMISSION OF WESTERN UNION IS STRICTLY PROHIBITED. Western Union Holdings, Inc. All Rights Reserved.

Table of ContentsSECTION 1. THE WESTERN UNION COMPANY GLOBAL AGENT COMPLIANCE PROGRAM MANUAL . . . . . . . . . . . . . . . . . . . . . . . . . 5

Legal Notice � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �5

Preventing Money Laundering and Terrorist Financing � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �6

Characteristics of Money Laundering and Terrorist Financing � � � � � � � � � � � � � � � � � � � � � � � � � � � �6

The Role of Western Union Agents � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �6

Initial and Ongoing WU Agent Due Diligence � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �7

Agent Compliance Program Reviews � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �7

Agent Compliance Program Assessment � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �9

Preventing Illicit Payments � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �9

SECTION 2. AGENT AML/CFT AND ANTI-FRAUD COMPLIANCE PROGRAM REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Evaluation of AML/CFT and Fraud Risk � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �10

Designated Agent Compliance Officer Responsibilities � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �10

Policies and Procedures � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �10

Regulatory Reporting � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �10

Training � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �11

Transaction Monitoring � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �11

Sanctions Compliance � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �11

Quality Assurance and Testing � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �12

The Agent Consumer Identification Processes � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �12

The F2 Zoom System � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �15

SECTION 3. SUB-AGENT OVERSIGHT PROGRAM REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Sub-Agent Due Diligence � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �16

Sub-Agent Training � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �16

SECTION 4. PREVENTING FRAUD AGAINST CONSUMERS AND AGENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Fraud Against the Consumer � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �17

Common Consumer Fraud Types � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �17


ATTENTION AGENTS: IF YOU, YOUR AGENT COMPLIANCE OFFICER OR ANY AGENT EMPLOYEES OR SUB-AGENTS HAVE QUESTIONS ABOUT ANY OF THE INFORMATION IN THIS MANUAL, PLEASE CONTACT YOUR DESIGNATED WESTERN UNION COMPLIANCE REPRESENTATIVE.

The WESTERN UNION name, logo and related trademarks and service marks, owned by Western Union Holdings, Inc., are registered or used in the U.S. and many foreign countries. THE INFORMATION CONTAINED IN THIS MATERIAL IS CONFIDENTIAL AND PROPRIETARY TO WESTERN UNION. ANY USE, COPYING, OR REPRODUCTION OF THIS MATERIAL WITHOUT THE PRIOR WRITTEN PERMISSION OF WESTERN UNION IS STRICTLY PROHIBITED. Western Union Holdings, Inc. All Rights Reserved.

Table of ContentsAssociate Requirements when Encountering Red Flags for Fraud � � � � � � � � � � � � � � � � � � � � � � � �19

Elevated Fraud Risk Agent Locations – the EFRAL Program � � � � � � � � � � � � � � � � � � � � � � � � � � �19

Fraud Against the Agent � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �20

Protecting the Agent from Fraud � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �21

Everyday Fraud Prevention Practices � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �22

SECTION 5. OTHER REQUIRED COMPLIANCE PROGRAM COMPONENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Prohibition Against Sending or Receiving Telemarketing Transactions � � � � � � � � � � � � � � � � � � � � �23

Data Protection and Privacy � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �24

Record Keeping and Record Retention � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �24

Law Enforcement Requests � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �24

APPENDIX A. FREQUENTLY ASKED QUESTIONS . . . . . . . . . . . . . 25Associate Training � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �25

The Role of the Compliance Officer � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �26

APPENDIX B. THE MODEL WESTERN UNION AGENT FRAUD POLICY AND PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

APPENDIX C. MONEY LAUNDERING, TERRORIST FINANCING, HUMAN TRAFFICKING, AND ILLEGAL GAMBLING RED FLAGS . 27

Money Laundering and Terrorist Financing Red Flags � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �27

Human Trafficking and Human Smuggling Red Flags � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �28

Illegal Gambling Red Flags � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �28

APPENDIX D. CONSUMER FRAUD RED FLAGS . . . . . . . . . . . . . . . 29Consumer Sending a Potentially Fraud-Induced Transaction � � � � � � � � � � � � � � � � � � � � � � � � � � � �29

Consumer Receiving a Potentially Fraud-Induced Transaction � � � � � � � � � � � � � � � � � � � � � � � � � �30

Potential Behavioral Red Flags for Fraud: � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �30

Potential Transaction-Related Red Flags: � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �30


The Global Agent Compliance Program Manual

This Agent Compliance Program Manual (“Manual”) and the Western Union Agent Compliance Program (“Agent Compliance Program”) requirements described herein are incorporated into and made a part of your agreement with Western Union as part of the Service Requirements.

New requirements described in this Manual include refusing transactions related to telemarketing activity, identifying and maintaining identification records on the Agent’s employees who have access to Western Union systems or who are involved in offering, or managing the offering of, our services to consumers (“Associates”) and their Sub-Agent’s Associates (which includes maintaining copies of Sales Associate identification documentation), enhanced Anti-Money Laundering and Counter Terrorist Financing program requirements, anti-fraud program requirements, and suspension and termination penalties for failing to meet the requirements set forth in this Manual.

This Manual also reiterates certain existing requirements, including that you must supply to Western Union and update your information such as ownership, address, tax identification documentation, any regulatory or criminal penalties, Sub-Agent due diligence, consumer identification processes, and program oversight by Western Union representatives.

Failure to implement the Agent Compliance Program as described in this Agent Compliance Program Manual may result in suspension or termination of your relationship with Western Union.

IMPORTANT NOTE: The term Agent is used in this Manual to mean a Network Agent, an Independent Agent, a Master Agent, and all Sub-Agents� This Manual applies to all Agents and their Sub-Agents that sell Western Union products and services� To be clear, Western Union requires all Sub-Agents to implement an Agent Compliance Program to the standard described in this Manual�

If you are a Network or Master Agent, you are responsible for ensuring that each of your locations understands and implements the requirements described in this Manual� If you have contracted with Sub-Agents, you must ensure that your Sub-Agents promptly receive a copy of this Manual, and understand and implement these program requirements at each Sub-Agent location�



Section 1. The Western Union Company Global Agent Compliance Program Manual The Western Union Company and its subsidiaries (“Western Union” or “WU”) have developed the Agent Compliance Program focused on, among other things, the detection, deterrence and prevention of money laundering (commonly referred to as anti-money laundering efforts, or “AML”), combatting the financing of terrorism (“CFT”), consumer protection, and anti-fraud. The Agent Compliance Program standards described in this Manual have been established to maintain the Western Union reputation in the marketplace, to comply with legal requirements and expectations, and to protect our consumers. As an Agent offering WU products and services, you are obligated to implement your own compliance program that incorporates the Agent Compliance Program requirements and which is designed to comply with the specific laws and regulations established in the country or countries where you operate.

This Manual describes the mandatory minimum standards for AML, CFT, and anti-fraud programs that WU requires you to implement as part of your compliance program. It also describes steps you should take to adopt these requirements. The Agent Compliance Program must be incorporated into the daily ongoing activity of your business. Your Associates should know the name and contact information for your compliance officer (the “Agent CO”), must complete all required training, and must follow all policies and procedures required in the Agent Compliance Program. The Agent must understand compliance requirements in their jurisdiction (including AML/CFT, consumer fraud, and consumer protection requirements), as well as the requirements described in this Manual.

Western Union has provided to you a model Anti-Fraud Policy and Procedures document for your use. If you have anti-fraud policies and procedures, you are required to review the model Agent Anti-Fraud Policy and Procedures and ensure that your program documentation includes (at a minimum) the model policy and procedure requirements. Failure to comply with the Agent Compliance Program, or the laws of the Agent’s country, may lead to serious action, including government fines and other penalties such as suspension or termination of your ability to offer Western Union services. WU is available to assist Agents if there are any questions about the Agent Compliance Program requirements in this Manual.

If you have Sub-Agents, you must promptly deliver this Manual and the model Western Union Anti-Fraud Policy and Procedures, attached to this Manual as Appendix B, to each of your Sub-Agents.

LEGAL NOTICEThis Manual describes the mandatory minimum Agent Compliance Program standards that you must implement to meet the compliance standards required by Western Union. This manual supplements the Service Requirements, but it does not describe the entirety of your legal obligations as an Agent of WU under your local laws and regulations, your contractual obligations to WU, or the obligations you owe to consumers. If any of the compliance requirements described in this Manual is less stringent than the compliance requirements in the country or countries where you operate, you are required to comply with the higher standard. If any requirement in this Manual contradicts with those in another Service Requirements document (including any WU policies) the requirements in this manual will govern. Please contact your Designated Western Union Compliance Contact if you, your employees, or Sub-Agents have any questions about the Agent Compliance Program requirements.



PREVENTING MONEY LAUNDERING AND TERRORIST FINANCINGWU and its Agents serve an important economic need by providing quick, safe, and reliable money transfer and payment services to consumers around the world. Through our global network of Agents, we can support the domestic and cross-border payment needs of our consumers, including expatriate workers providing funds to families in their home country, students studying abroad, or disaster relief workers needing access to funds. However, by providing this service, WU and its Agents are vulnerable to being used by criminals to move funds for illegal purposes, or to defraud others. WU takes its AML/CFT, and fraud prevention programs seriously and expects that you will do the same.

The Agent Compliance Program requirements described in this Manual are designed to help you detect, deter, and prevent money laundering, terrorist financing and consumer fraud, and to lower the risk that consumers or the Agent’s employees will use the WU network for illegal or illicit purposes. It is important that you are aware of these Agent Compliance Program requirements to help protect you and your business, to comply with AML and CFT laws, and to support national and international efforts against crime and terrorism.

CHARACTERISTICS OF MONEY LAUNDERING AND TERRORIST FINANCINGMoney laundering is the act of separating the proceeds of crime from the crime itself to hide an individual’s connection to that crime. Money launderers sometimes try to use financial institutions like banks and money transmitters to hide the origin of their funds or to obscure a transaction’s criminal purpose. Terrorists also attempt to conceal their financial activities to avoid detection. Those who help criminals and terrorists in such efforts are subject to criminal prosecution themselves. There are many techniques, described in Appendix C, that money launderers and terrorists use, and these techniques evolve over time in response to the controls established by governments and financial institutions.

THE ROLE OF WESTERN UNION AGENTS Western Union relies on its Agents to be the first line of defense against the abuse of WU services. As such, you and your Associates have a critical role to play in the detection and prevention of money laundering, terrorist financing, and consumer fraud. As a WU Agent, you must read, understand, and implement the requirements described in this Manual and in the model Agent Anti-Fraud Policy and Procedures.



This Manual requires you to contact Western Union in certain situations. For Agent Compliance Program questions, please contact your Western Union Dedicated Compliance Contact. For all non-compliance issues or questions, please contact your Designated Western Union Operations Contact, unless otherwise directed in this Manual.

INITIAL AND ONGOING WU AGENT DUE DILIGENCEWestern Union performs due diligence on all new and renewing Agents as part of the Agent enrollment and recertification processes. Along with collecting certain information about your company’s owners, key management, legal structure, and business history, WU must also validate this information by collecting company formation documents. Western Union requires due diligence information before an Agent may transact with Western Union, and throughout the relationship. You are required to update this information when it changes over time. This process, called the Agent due diligence or Know Your Agent (“KYA”) process, ensures that our due diligence information remains accurate, complete, and up-to-date throughout the life of our relationship.

Along with company information and documentation, Western Union will request, at a minimum, the following information (as well as an identification document that verifies this information) from the Agent’s owners and at least one senior level manager: (i) first and last name(s); (ii) city and country of residence; (iii) date(s) of birth; (iv) country of birth; (v) identification date of issuance; (vi) identification expiration date; and (vii) tax identification number. Western Union also requires information on the Agent’s past record of legal and regulatory compliance, the expected volume of transactions, a description of the typical consumer who will use the location to send funds, and the countries where these consumers will be sending funds.

Western Union requires all Agents to respond to a compliance questionnaire with certain information and documentation. Your response must be complete and accurate. If you do not complete the questionnaire with complete and accurate information, new Agent relationships may be prevented and existing Agent relationships may be suspended or terminated.

Agents must also provide updated information and supporting documentation to WU whenever important changes occur in your business, or the business of any

of your Sub-Agents, and upon WU request. Specifically, you must notify your WU Compliance Contact promptly if any of the following occurs:

• a change in business address of the Agent or of the Agent’s Sub-Agents;

• a change in the Agent or Sub-Agent’s tax identification number;

• a change in ownership of the Agent or your Sub-Agents (WU policy requires identification information on persons who own 10% or more of the business);

• closure or suspension of any Agent or Sub-Agent locations, or the suspension or termination of any agreement with a Sub-Agent; and

• the company, its owners, Associate’s, or key members of its management team are charged, convicted, or plead guilty/no contest to a serious criminal act such as bribery, graft, political corruption, counterfeiting, forgery, drug trafficking or distribution, fraud, money laundering, organized crime, human or organ trafficking, terrorist related crimes, or other financial crimes or crimes of dishonesty.

AGENT COMPLIANCE PROGRAM REVIEWSWestern Union provides compliance support to its Agents to ensure that there is a strong understanding of Agent compliance responsibilities. A WU Compliance Support Team is available to answer any questions you may have about your compliance requirements. New Agents will be contacted by the WU Compliance Support Team to ensure there is an understanding of the Agent Compliance Program described in this Manual. Agents should use these meetings to ask their WU Compliance Contact any questions they may have about the compliance standards in this Manual as well as other Agent Service Requirements.

In addition to the new Agent compliance discussions, WU performs periodic risk assessments on all its Agents to determine which Agents will be reviewed by WU Compliance Contacts. Agents are selected for review based on their transaction volume, countries to or from which they send funds, the risk level of their consumers’ transactions, and other factors. If selected for review, you will be notified by a WU Compliance Contact, who will perform a review of your compliance program. This review is an essential element of the Western Union Agent oversight process.



Western Union will send a letter notifying selected Agents of an upcoming compliance review. A Western Union Compliance Contact will then communicate with you by telephone or e-mail to schedule the review. During the review, the Western Union Compliance Contact will ask you several questions about your Agent compliance program and will review relevant documents and records. Western Union requires the full cooperation and attention of your Agent CO at this meeting.

The Agent CO must make the following information available to the Agent’s Designated Western Union Compliance Contact for the review:

• a completed Designation of Compliance Officer form

• compliance and fraud awareness training

• compliance training logs showing all compliance training events

• evidence of the Agent’s transaction monitoring process

• current identification document logs for the money transfer system showing unique identification documents for each system user

• if the Agent sells money orders, current user identification document logs for the money order system showing unique identification documents for each user

• the most current version of the Agent’s compliance policies and procedures required in this Manual

• any suspicious activity or suspicious transaction reports (“SARs/STRs”) that have been referred to Western Union, along with evidence of retention for the legally-required time period

• for Agents in the U.S. and Canada only: If the Agent sells Money Orders, the Money Order log for the legally required time period

The Western Union Compliance Contact may also request additional information, including but not limited to:

• information related to a filed SAR/STR or interdiction request

• information on reported fraudulent transactions sent or paid out by an Agent

• information regarding a consumer fraud or service complaint

• information on unusual patterns of activity that have been identified by your transaction monitoring system



AGENT COMPLIANCE PROGRAM ASSESSMENTUpon completion of the compliance review, the WU Compliance Contact will leave a Program Review Report which identifies any parts of the Agent Compliance Program that require attention. Simple administrative items may be corrected on site during the review. More significant issues, such as completing training, filing SARs/STRs, or enhanced transaction monitoring, may take time to address. Your Western Union Compliance Contact will establish an acceptable time frame for remediation and will follow up to ensure that these issues were effectively addressed.

PREVENTING ILLICIT PAYMENTSThe importance of the Associate in your risk management process and in carrying out the Agent Compliance Program cannot be overstated. The Associate has direct contact with the consumer at the point-of-sale. How a consumer behaves when sending or receiving funds can indicate that a transaction might be suspicious. Additionally, if the transaction doesn’t make sense to the Associate it may not be for legitimate purposes.

All Associates must be trained to recognize behavioral and transactional characteristics indicative of money laundering and terrorist financing, fraud, or other illegal or impermissible activities (“red flags”). If the Associate witnesses red flag activity, the Associate should not process the transaction. If the Associate is concerned for their safety or the safety of others, the Associate may process the transaction but must immediately report the situation to their WU Compliance Contact. Please refer to Appendices C and D for examples of money laundering, terrorist financing, and fraud red flags.

You must have a clear, written process on how an Associate is to respond to and report red flag activity. If you or your Associate suspects that money laundering, terrorist financing or fraud has occurred, you may be required by your country’s law to file SARs/STRs.



Section 2. Agent AML/CFT and Anti-Fraud Compliance Program RequirementsAt a minimum, your AML/CFT and anti-fraud Compliance Program must include the program components described in this Section.

EVALUATION OF AML/CFT AND FRAUD RISKAs a WU Agent, you must identify the types of consumers and transactions that are likely to pose a higher risk of money laundering, terrorist financing, and consumer fraud. You must also learn your country’s AML and CFT laws and regulations to ensure that you are complying with both local law and these Agent Compliance Program standards.

Issues that you should consider when evaluating the compliance risk consumers present to your business include details about your Agent location (for example, is it near a border where there is a lot of cross-border transaction activity?); the typical consumer that uses your location (for example, are the consumers local to the area, tourists, or immigrants from countries that have high levels of money laundering, fraud, or terrorism?); and the countries where a typical consumer transfers funds to (whether the countries have a high level of fraud, money laundering, or terrorism?). Once these issues are identified, you can use the information to determine your overall compliance risk and establish controls such as stopping concerning transactions before they are sent, calling your Western Union Compliance Contact, or ensuring that consumer identification documentation is correct.

DESIGNATED AGENT COMPLIANCE OFFICER RESPONSIBILITIES Each Agent must designate an Agent CO who is responsible for establishing and overseeing the Agent’s compliance program. The Agent CO has overall responsibility for implementing and maintaining the Agent’s AML/CFT and anti-fraud compliance programs and must complete all required compliance training.

You must provide WU with a written description of the Agent CO’s identity, and must demonstrate that the Agent CO understands the compliance laws and regulations in your jurisdiction(s) as well as the Agent Compliance Program standards described in this Manual. You must provide your Agent CO with sufficient resources and authority to execute their responsibilities effectively, and shall authorize and empower the Agent CO to play a central role in your Agent compliance program. The Agent CO must also have the responsibility

and authority for ensuring that the AML/CFT and anti-fraud program requirements described in this Manual have been appropriately implemented.

Regardless of the size of your business, you must avoid potential conflicts of interest. To enable unbiased judgments and facilitate impartial advice to management, it is best practice for the Agent CO not to have business line responsibilities, nor should the Agent CO be responsible for the mandatory independent review function required by the Agent Compliance Program and described in this Manual. Where conflicts between business and Agent CO responsibilities are unavoidable, such as with smaller organizations, procedures should be in place to ensure the objective management of AML, CFT, fraud, and consumer protection matters.

POLICIES AND PROCEDURESYour compliance program must include documented policies and procedures designed to detect, deter, and prevent AML, CFT, and fraud, as well as the other components of the Agent Compliance Program described in this Manual or elsewhere in the Service Requirements. Along with AML/CFT and consumer fraud policies, you must also have written procedures that are clearly understood by your Associates and that describe the day-to-day processes for implementing the policies. For example, you should have written procedures for collecting consumer identification when required, transaction monitoring, escalating compliance issues to your Agent CO when necessary, managing consumers who demonstrate suspicious behavior and filing SARs/STRs with appropriate authorities (as required in your jurisdiction(s), and maintaining all compliance and transaction records, and sensitive consumer data, in a reliable and secure location and in accordance with WU record retention timelines and applicable legal requirements. Your policies and procedures must be communicated at least annually to all Associates offering or supporting WU products and services. Front Line Associates must acknowledge that they have read and understood your written AML/CFT and consumer fraud policies and procedures.

REGULATORY REPORTINGYour compliance program policies and procedures should enable the timely identification of transactions that are reportable under the AML or other laws in your country or countries of operation in the mandated media (electronic or paper filing) and format.



Even if there is no country requirement to file SARs/STRs, you are expected to escalate suspicious consumer behavior or activity to WU for further review once you have completed your internal investigation. Where required by law, Agents must directly inform their local government or law enforcement authorities as well. To facilitate these escalations and referrals, you must establish a clearly communicated written process for your employees to report suspicious activity concerns to the Agent CO.

TRAININGTraining on compliance program standards and processes is essential for all Associates and the Agent CO. Your compliance program must include ongoing training to ensure that all relevant Agent employees (including Sub-Agents and their Associates, if applicable) are adequately trained on the Agent Compliance Program requirements.

No Agent employee will have access to the WU systems, and you may not permit any employee to offer any WU products or services to the public, unless the employee has completed AML/CFT, consumer and agent-victim fraud, and consumer protection training. New Associates and Agent COs must attend training as soon as possible after being hired. Adequate refresher training should be provided on an ongoing basis, and particularly when there are significant changes to processes, systems, risks, or Agent Compliance Program standards to ensure that employees are reminded of their obligations, and that their knowledge and expertise are kept up-to-date.

The Agent Compliance Program must require that all employee training be documented and reflect the names of attendees, the dates of attendance, the method of delivery, and the training content. Training records must be maintained according to applicable record keeping rules.

While there are many ways to deliver training to new and existing employees, WU offers access to an online training program, “Agent Academy,” that is available 24 hours a day, 7 days a week through the Western Union Learning Management System. Agent Academy may be accessed through the Western Union Agent Portal once

Associate credentials have been established. WU also provides training outside of Agent Portal for Agents that are not able to access online training.

For Agent Portal access in the United States and Canada, please log in to: https://agentportal.westernunion.com/ap/loginap.do

For Agent Portal access outside of the United States and Canada, please log in to: https://wuagentportal.westernunion.com/ap/login.do

Your Designated Compliance Contact or Operations Contact can facilitate your access to WU-provided training.

TRANSACTION MONITORINGYour Agent compliance program must include documented policies and procedures to ensure monitoring of WU transactions for money laundering, terrorist financing, and consumer fraud activity. However, the degree and nature of monitoring will vary by Agent and will depend on the size of your business, the AML/CFT and fraud risks at the location, the monitoring method being utilized (manual, automated or some combination), and the type of activity under scrutiny.

If you operate in a jurisdiction that mandates SAR/STR reporting, the Agent Compliance Program must enable the timely identification of transactions that are reportable under the law in your country or countries of operation. The Agent’s policies and procedures must ensure accurate and timely filing of SARs/STRs.

The results of the monitoring must be documented, either systematically, manually, or both, to create a comprehensive audit trail of the investigation, transactions, and report filing. These records must be maintained according to the recordkeeping rules described in this Manual under “Recordkeeping Requirements.” If you need assistance with your monitoring processes, please contact your Dedicated Western Union Compliance Contact.

SANCTIONS COMPLIANCE Economic and trade sanctions serve important security and foreign policy goals, and may range from comprehensive country embargoes to more targeted measures such as freezing assets, arms embargoes, and travel bans. National governments and multilateral institutions have applied sanctions to support peaceful transitions, deter non-constitutional changes, constrain terrorism and drug-trafficking, protect human rights, and promote non-proliferation of weapons of mass destruction. Western Union is subject to many economic and trade sanctions laws, rules and regulation, and complies globally with sanctions implemented by the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC “) and the United Nations.

Western Union also complies with other applicable government economic and trade sanctions programs

https://agentportal.westernunion.com/ap/loginap.do

https://wuagentportal.westernunion.com/ap/login.do



mandated by the countries, territories, and jurisdictions where our products and services are sold. In accordance with the company’s current sanctions compliance policies, Western Union does not provide money transfer services to, from or involving Iran or North Korea, and strictly limits its activity involving Cuba, Syria, Sudan and the Crimea region. Western Union will terminate its relationship with Agents if they (or their Sub-Agents) are suspected of knowingly facilitating any transaction that directly or indirectly involves activity unauthorized by OFAC or by WU Global Sanctions Policy in these countries and regions, or for circumventing or attempting to circumvent WU sanctions controls.

Agents play a critical role in supporting the Western Union sanctions compliance program, and we expect you to avoid taking action that would cause us to violate applicable sanctions rules and regulations or our sanctions compliance policies. WU has established standards, guidelines, procedures, and controls that specify practices to obtain the most reliable information possible at the time of the transaction, and to ensure that the transaction is not processed in a manner that would mask the identity of relevant parties from our transaction screening. Agents must collect complete and unaltered information on all senders and receivers of WU transactions. Without complete and accurate identification information, it is difficult for both the Agent and WU to comply with sanction laws. If an Agent is found to be intentionally altering or assisting a consumer to alter identification information to avoid the economic sanctions laws, WU will terminate its relationship with the Agent.

Agents must also comply with sanctions regulations and rules applicable to them, and must ensure they do not engage Sub-Agents subject to OFAC, UN or other applicable economic and trade sanctions. Agents should take a risk-based approach in determining whether other controls may be necessary or advisable to mitigate the risk of violations of applicable sanctions laws, rules, and regulations.

QUALITY ASSURANCE AND TESTINGAgents must have a quality assurance program that performs regular and independent testing of the AML/CFT and fraud controls. The testing program must also assess the effectiveness of AML/CFT and fraud controls such as transaction monitoring, employee training, and regulatory reporting. This independent testing should be conducted by qualified parties who are not involved in the implementation or operation of your compliance program. This testing should evaluate the adequacy of your program.

Your compliance program must include reviews of new Associates to ensure that they understand job requirements such as when to collect a consumer’s identification, how transaction data fields must be completed, when to call Western Union if there is a question about a transaction, how to identify and report AML/CFT, human trafficking, and fraud red flag activity, or any other Agent Compliance Program standard. If the quality assurance review determines that an employee needs additional training, you must provide this training to ensure that your processes are performed accurately.

THE AGENT CONSUMER IDENTIFICATION PROCESSESYour compliance program must account for, and comply with, WU consumer identification rules, as well as any local law applicable to you or WU services. It is your responsibility to ensure that the AML/CFT laws in your country are well understood and enforced by your employees, including all full time, temporary, and any contract employees. To assist you, WU has implemented consumer identification controls at the point-of-sale. These controls, which may be revised from time-to-time, are designed to ensure that Agents collect and enter all necessary information into the WU system before sending or paying out a transaction.

CONSUMER DUE DILIGENCE MEASURESThe WU point-of-sale system requires that additional consumer due diligence (“CDD”) measures be taken for higher risk transactions. These measures could include additional identification documents, or asking the consumer questions about the purpose of the transaction or the source of the funds they are sending or receiving. At a minimum, you must collect all required information to verify that the person sending or receiving funds is who they say they are. CDD requirements are designed to assist Agents in effectively identifying, verifying, and monitoring their consumers and the financial transactions in which they engage, in relation to the money laundering, terrorist financing, fraud and consumer protection risks that they pose.

PROHIBITED INDUSTRIESTo protect our brand and the people who use our services, Western Union Agents may not participate in, or knowingly process, a transaction for a company that operates in an industry listed in the table below. Additionally, Western Union Agents may not onboard a Sub-Agent if that Sub-Agent participates in any of the industries described in this table.



Industry Description of Prohibitions Concern

Illegal Gambling Western Union Agents will not knowingly transmit, establish a business relationship with, or process payments on behalf of illegal gambling organizations, or persons who have engaged in illegal gambling.

Western Union Agents may not place, receive, or otherwise knowingly transmit a bet or wager by any means, where such bet or wager is unlawful under any applicable law in the jurisdiction in which the bet or wager is initiated, received, or otherwise made.

Shell Banks Western Union Agents will not knowingly process payments, or allow the use of Western Union services by shell banks.

A shell bank is a bank that has no physical presence in the country in which it is incorporated and licensed, and which is unaffiliated with a regulated financial group that is subject to effective consolidated supervision. Physical presence means meaningful physical presence and management located within a country. The existence simply of a local bank Agent or low- level staff does not constitute physical presence.

Telemarketing Companies

Western Union Agents will not knowingly conduct transactions to or from telemarketers or process payments for goods or services solicited through telemarketing.

Although telemarketing is a legal industry, money transmitters in the United States are prohibited from providing cash transaction services to the industry. Because telemarketing activity outside of the United States could potentially require cash payments into or out of the United States, this activity is being prohibited globally. Agents worldwide must adhere to Western Union policies and procedures designed to prevent such transfers.

Prostitution Western Union will not knowingly process payments or allow the use of Western Union services by companies in the prostitution industry, even if the industry is legal in the Agent’s country of operation.

Although prostitution may be legal in certain jurisdictions, Western Union will not do business with this industry.

Marijuana Industry and other Recreational Drug Industries

Western Union Agents will not knowingly process payments or allow the use of Western Union services by Marijuana or other Recreational Drugs Industries.

Although marijuana or other recreational drugs may be legal in certain jurisdictions, Western Union will not do business with this industry.



Industry Description of Prohibitions Concern

Unlicensed Financial Institutions, where licensing is required

In jurisdictions that require financial institutions to be licensed, Western Union Agents will not knowingly open accounts, process payments, or allow the use of Western Union services by Unlicensed Financial Institutions.

Western Union will not knowingly open accounts, process payments, or allow the use of Western Union services by financial institutions that do not hold required licenses or registrations in their jurisdictions. The term “Financial Institution” means a bank; a trust company; a private banker; a credit union; thrift institution; broker dealer in securities or commodities; an investment banker or investment company; a currency exchange; an issuer, redeemer, or cashier of travelers’ cheques, cheques, money orders, or similar instruments; an operator of a credit card system; an insurance company; a dealer in precious metals, stones, or jewels; a pawnbroker; a loan or finance company; a travel agency; a money transmitter; a telegraph company; a business engaged in vehicle sales, including automobile, airplane, and boat sales; person involved in real estate closings and settlements; or a casino, gambling or gaming establishment.

Rough Diamond Trade Western Union Agents will not knowingly process payments, or allow the use of Western Union services when there is suspicion of being involved in the misuse of the rough diamond trade protocols.

Any entity that imports or exports rough diamonds, from whatever source, not controlled through the Kimberley Process Certification Scheme.

Counterfeit/Pirated Goods

Western Union Agents will not knowingly process payments, or allow the use of Western Union services when there is reasonable suspicion of being involved in the making of counterfeit or pirated goods.

Counterfeiting and piracy are issues that impact a wide variety of industries and can expose Western Union and its Agents to significant legal risk.

Illegal Activities In addition to activities that may be legal but are prohibited by Western Union policy, Western Union Agents may not knowingly process payments, or allow the use of Western Union services when there is suspicion of illegal activity.

This section refers to illegal activities that are defined by the law where the Agent Location operates, which may not have been described elsewhere in this table.



THE F2 ZOOM SYSTEMThe WU F2 Zoom system contains information about our products and services (including any specific transaction restrictions, limitations, conditions, or rules) for every country where they are available. All Associates should be trained on how to use the F2 Zoom system to assist consumers with their transactions. A consumer sending funds may not understand why their transaction has been stopped, but the reason likely can be found in this system.

The F2 Zoom system contains information such as:

• available sending and payout currencies for the transaction

• any sending or payout transaction restrictions

• consumer test question rules

• relevant time zones for the transaction so the consumer understands when the funds will be available to the receiver

• acceptable forms of identification for a country, such as driver’s license, passport or national insurance card, and

• holidays for the current year, to inform the consumer if a holiday in the payout country will impact the time when the funds can be available to the receiver.

Before sending a WU transaction, the Associate must first check F2 Zoom to ensure that the Associate is aware, and makes the consumer aware, of regulations that govern each side of the transaction (send and payout), and to set consumer expectations. For example, if payout locations will be closed that day due to a local holiday, the Associate should inform the consumer that the funds will be available for pickup by their receiver on the day following the holiday. You must promptly inform your Designated WU Operations Contact if you become aware of any new rules, restrictions, or details that need to be included in F2 Zoom for your location(s).



Section 3. Sub-Agent Oversight Program RequirementsIf you have contracted with Sub-Agents, your compliance program must establish policies and procedures to identify the owners of any Sub-Agents, as well as to evaluate the operations of those Sub-Agents. You must also oversee their implementation of policies, procedures, and controls designed to minimize the risk that WU products and services will be used for illegal or illicit purposes by the Sub-Agent’s consumers, or Associates. Agents should provide guidelines to help Sub-Agents develop their own compliance programs that comply with the Agent Compliance Program and the requirements set forth in this Manual or elsewhere in the Service Requirements. You must promptly provide Sub-Agents with any updated copies of this Manual (which will be amended from time-to-time) as well as any Western Union model AL/CFT or anti-fraud policy and procedure document(s).

Master Agents are responsible for ensuring that their Sub-Agents implement the compliance program standards described in this Manual at each Sub-Agent location, including providing training each location.

When an Agent contracts with a new Sub-Agent, the Agent must provide the Sub-Agent with Western Union Agent compliance materials and tools, including this Manual, and ensure that the Sub-Agent understands their compliance obligations including AML/CFT program standards, anti-fraud compliance program responsibilities, and the Agent’s policies and mandated controls.

The Agent must also:

• Promptly attend to and remediate Sub-Agent compliance program deficiencies, which may result in further training, probation, suspension or termination of the Sub-Agent.

• Provide guidelines and assistance to the Sub-Agent to help the Sub-Agent develop their own AML/CFT compliance program.

• Ensure each Sub-Agent’s compliance program adheres to all Agent Compliance Program standards, policies, and regulations, including the applicable regulatory reporting, monitoring, and recordkeeping standards.

Agents must periodically review the adequacy of each of its Sub-Agent’s compliance programs. Western Union holds its Agents accountable for the actions of their Sub-Agents. Agents must suspend or terminate Sub-Agents that are not in compliance with the standards in this

Manual. If Western Union determines that an Agent is not exercising sufficient Sub-Agent oversight, Western Union may suspend or terminate the Agent.

SUB-AGENT DUE DILIGENCE To conduct proper due-diligence, the Agent must, at a minimum, collect the following information from the Sub-Agent owners and at least one senior level manager and make this information available to WU: (i) first and last name(s); (ii) city and country of residence; (iii) date(s) of birth; (iv) country of birth; (v) identification date of issuance; (vi) identification expiration date; and (vii) identification number. The Agent must understand the Sub-Agent’s past record of legal and regulatory compliance, the expected volume of transactions, the Sub-Agent’s typical consumer, and the countries where these consumers will be sending transactions.

Agents must understand the reason for their Sub-Agent changing from another money transfer service provider (if applicable), the length of time the prospective Sub-Agent has been in business as a money transfer provider (if applicable), the ownership structure, creditworthiness, financial viability, class of trade or industry, and any license or registration the Sub-Agent may be required to hold. Due diligence must be updated periodically thereafter. It is expected that you will ensure that all Sub-Agents and their owners and directors are not subject to applicable sanctions, (including those maintained by OFAC and the United Nations). Agents must ensure that none of their Sub-Agents or any Sub-Agent’s owners or directors have previously been an Agent, Sub-Agent, owner, or Associate of an Agent or Sub-Agent that has been suspended or terminated for fraud-related reasons by Western Union or any other money transfer company. You must provide all Sub-Agent due diligence information to Western Union before the Sub-Agent will be considered for approval by Western Union

SUB-AGENT TRAININGOnce an Agent contracts with a new Sub-Agent, the Agent must conduct new Sub-Agent training that describes the program standards in this Manual. This training should address the Agent Compliance Program requirements with respect to AML, CFT, fraud, and consumer protection, as well the Agent’s policies and controls, and local law. It is appropriate for the Agent to assist their Sub-Agents by providing compliance materials and other tools. You must provide training to Sub-Agents and their Associates on an ongoing basis.



Section 4. Preventing Fraud Against Consumers and AgentsWestern Union Agents must take active steps to prevent consumer fraud.

Consumer fraud occurs when criminals convince or trick consumers to transfer money to the criminal or the criminal’s associates. Criminals use a variety of scams to perpetrate such crimes, and they often target the most vulnerable members of society—particularly the elderly. It is therefore imperative that Agents are always aware of potential fraud-related activity.

Consumer fraud generally involves criminals conducting scams to persuade consumers to transfer money to them that might sound financially appealing to the consumer, but are in fact an attempt to steal from the consumer. Most consumer fraud involves the victim’s perception that they will receive some sort of financial gain or that they are helping a friend, relative, or loved one. A common theme in all consumer fraud schemes is that the consumer has never met the receiver in person. All WU Agents must take the steps described in this Manual to detect, deter, and report consumer fraud.

FRAUD AGAINST THE CONSUMERYour compliance program must include policies and procedures designed to detect, deter, and report consumer fraud, and which comply with the Agent Compliance Program standards. You may use the model WU Agent Fraud Policy and Procedures, attached as Appendix B if you do not have policies and procedures established for your anti-fraud program. You must also comply with any local anti-fraud laws in the country or countries where you operate. Your Associates must be trained on consumer fraud and you must document processes that allow Associates to prevent transactions they suspect are fraudulent, and report known or suspected fraud, or fraud complaints, to Western Union.

COMMON CONSUMER FRAUD TYPESAll Associates must be trained to recognize the following common types of consumer fraud scams so they can help protect consumers from becoming victims.

ADVANCED FEE OR PREPAYMENT SCAMVictim is asked to pay upfront fees for financial services which are never provided. Victims often send a succession of transactions for payment of various upfront fees. Methods: credit card, grant, loan, inheritance, investment.

ANTI-VIRUS SCAMVictim is contacted by someone claiming they are from a well-known computer or software company and a virus has been detected on the victim’s computer. The victim is advised that the virus can be removed and the computer protected for a small fee with a payment by either credit card or a money transfer. In reality, there was no virus on the computer and the victim has just lost the money they sent for the protection.

CHARITY SCAMThe victim is often contacted by e-mail, mail or phone by someone asking for a donation to be sent by money transfer to an individual to help victims of a recent current event, such as a disaster or emergency (such as a flood, cyclone, or earthquake). Legitimate charity organizations will never ask for donations to be sent from one individual to another individual through a money transfer service.

EMERGENCY SCAMVictim is led to believe that they are sending funds to assist a friend or loved one in urgent need. Victim sends the money with urgency as the victim’s natural concern for a loved one is exploited.

EMPLOYMENT SCAMVictim responds to a job posting and is hired for the fictitious job and sent a fake cheque for job related expenses. Cheque amount exceeds the victim’s expenses and victim sends remaining funds back using a money transfer. The cheque bounces and the victim is responsible for the full amount.

FAKE (COUNTERFEIT) CHEQUE SCAMVictims are often sent a cheque as a part of a scam and told to deposit the cheque and use the funds for employment expenses, internet purchases, mystery shopping, etc. The cheque is fake (counterfeit), and the victim is left responsible for any funds used from the cheque. Remember, funds from a cheque deposited into an account should not be used until the cheque officially clears, which can take weeks.

GRANDPARENT SCAMThis scam is a variation on the Emergency Scam. The victim is contacted by an individual pretending to be a grandchild in distress, or a person of authority such



as a medical professional, law enforcement officer, or attorney. The fraudster describes an urgent situation or emergency (bail, medical expenses, emergency travel funds) involving the grandchild that needs a money transfer to be sent immediately. No emergency has occurred, and the victim who sent money to help their grandchild has lost their money.

IMMIGRATION SCAMVictim receives a call from someone claiming to be an immigration official saying there is a problem with the victim’s immigration record. Personal information and sensitive details related to the victim’s immigration status may be provided to make the story seem more legitimate. Immediate payment is demanded to fix any issues with the victim’s record and deportation or imprisonment may be threatened if payment is not made immediately by money transfer.

INTERNET PURCHASE SCAMThe victim sends money for the purchase of item ordered online (e.g. pets, cars). Items are often advertised on Craigslist, eBay, Alibaba, etc. After the money is sent, the victim never receives the merchandise.

TAX SCAMVictim is contacted by someone claiming to be from a governmental agency saying that money is owed for taxes, and it must be paid immediately to avoid arrest, deportation or suspension of driver’s license/passport. The victim is instructed to send a money transfer or purchase a pre-loaded debit card to pay the taxes. Government agencies will never demand immediate payment or call about taxes without first having mailed a bill.

LOTTERY OR OTHER PRIZE SCAMVictim is told that they have won a lottery, prize or sweepstakes and that money must be sent to cover the taxes or fees on the winnings. The victim may receive a cheque for part of the winnings and once the cheque is deposited and money is sent, the cheque bounces.

MYSTERY SHOPPING SCAMThe fraudster contacts the victim through an employment website, or the victim responds to an ad about an employment opportunity to evaluate a money transfer service. The fraudster often sends the victim a cheque to deposit and instructs the victim to send a

money transfer, keeping a portion of the cheque for their pay. The victim sends the money, the fraudster picks it up, and when the cheque bounces the victim is left responsible for the full amount.

OVERPAYMENT SCAMThe fraudster sends the victim a cheque that appears to be valid as payment for a service or product. Typically, the amount of the cheque exceeds what the victim expects to receive, and the fraudster tells the victim to send the excess back using a money transfer. When the cheque bounces, the victim is left responsible for the full amount.

RELATIONSHIP SCAMVictim is led to believe that they have a personal relationship with someone they met online often by social media, in an online forum or on a dating website. The victim is often emotionally invested, often referring to the recipient as a fiancée and believes they are sending money for travel or medical expenses. In the end, the fraudster is stealing from the victim and no relationship is every formed

RENTAL PROPERTY SCAMVictim sends money for deposit on a rental property and never receives access to the rental property or the victim may also be the property owner who is sent a cheque from the renter and asked to send a portion of the cheque back using a money transfer and the cheque bounces.

NOTE: All elder and dependent adult consumers should be asked if they have met the person they are sending money to because they are highly vulnerable to telephone or online fraud� If it becomes clear that the sender is not sure if the receiver is legitimate, then the Associate should refuse to process the transaction� If the elder person is sending to a grandchild, the Associate must always ask the grandparent if they have called their grandchild to verify that the emergency is real�



ASSOCIATE REQUIREMENTS WHEN ENCOUNTERING RED FLAGS FOR FRAUDCareful observance of consumer behavior is an important function in identifying potentially illegal or fraudulent activity. A “red flag” is an observable situation or fact that could indicate fraudulent or illegal behavior. Red flags may be noted by observing a consumer’s behavior. For example, a consumer may act nervous, apprehensive, or confused, or be reluctant or unable to provide basic details about the sender, receiver, or purpose of the transaction. Other times the consumer may not know specific details related to their transactions. The consumer may conduct multiple transactions in small or odd amounts, or multiple transactions to multiple receivers in various locations. If the Agent has “hotkey” capability, the Agent should use the hotkey system to alert WU that a transaction related to consumer fraud has been attempted.

Please refer to Appendix D for examples of consumer fraud red flags. These red flags are provided as guidelines for preventing fraud, but they also can be used as fraud transaction patterns for monitoring purposes. If the Associate notices any consumer fraud red flags and suspects that the receiver may be picking up a fraudulently induced transaction, the Associate may perform the following actions:

• Ask for a second form of identification. The second form of identification could be any form of document which would match the name on the first form of identification presented—for example, a utility bill or a library card.

• Ask additional, open-ended KYC questions with the purpose of making the receiver think about their responses. Pay attention to not only the receiver’s answers to the questions, but also the receiver’s behavior (do they become nervous or struggle to answer?). Examples of open-ended KYC questions are:

� “What is your relationship to the sender?”

� “Where and when did you first meet the sender?”

� “What is the purpose of the transaction?”

� “How often do you use Western Union?”

� “Were you directed to receive this transaction by someone else?”

• Refuse to payout the transaction and inform the receiver that the transaction is not available at that time.

• Follow procedures to complete an STR/SAR, if required by the law for your location(s).

If the Agent determines that a fraud-induced transaction has occurred at the location, or if a consumer submits a complaint to the Agent stating that they were defrauded, the Associate should report the following information to the Western Union Fraud Hotline:

• the consumer’s name, address, and telephone number

• the substance of the complaint including the fraud type and fraud method, and the name of any person referenced

• the reference number or Money Transfer Control number, for each money transfer related to the complaint

• The name, agent identification number, telephone number, and address of the receiving agent(s)

• the date of each money transfer

• the amount of each money transfer

• the money transfer fee for each money transfer

• the date each money transfer is received

• the name, Agent identification number, telephone number, and address of the receiving Agent(s)

• the name, address, and telephone number of the recipient, as provided by the recipient, of each money transfer

• the identification, if any, presented by the recipient, and recorded, for each money transfer

• all transactions conducted by the consumer bearing any relationship to the compliant.

ELEVATED FRAUD RISK AGENT LOCATIONS – THE EFRAL PROGRAMThe purpose of the Elevated Fraud Risk Agent Location (“EFRAL”) program is to reduce and prevent consumer fraud and to continue to take measures to protect the interests of our consumers, our Agents, and the Western Union brand. An EFRAL means any Western Union Agent location that has processed money transfer payouts associated with:

• five (5) or more fraud complaints for such Agent locations, received by Western Union from any source, during the previous sixty (60) day period and representing five percent (5%) or more of the total payouts for such Agent location in numbers or dollars during the same period, measured monthly, or

• fifteen (15) or more fraud complaints for an Agent location received from any source during the previous sixty (60) days based on a monthly review of complaints



If an Agent location meets the EFRAL criteria, all WU money transfer products and services will be suspended. Your Designated Western Union Compliance Contact will notify you prior to the suspension being implemented. Western Union will investigate the consumer complaints that led to the location being designated as an EFRAL. We encourage you to do the same, and to partner with WU to assess underlying causes for the designation. Based on the investigation assessment, you must take additional steps to mitigate the risk of future occurrences. Your Dedicated WU Compliance Contact can work with you to develop a comprehensive plan that enables reactivation of the location.

You must actively participate in fraud detection and deterrence at your location(s). You must develop internal processes designed to detect, deter, and report fraud-induced transactions. Western Union is available to assist you if you have any questions about the requirements of the EFRAL program.

FRAUD AGAINST THE AGENTAgents and their locations can be victims of fraud. Agents should implement written procedures for managing the risk that you will be a victim of fraud.

PROTECTING AGAINST AGENT VICTIM FRAUDAgent victim fraud is fraud perpetrated against the Agent location that results in a financial loss for the location. Fraud against Agents can happen in different ways. Below are common methods for defrauding Agents. Please note that these scenarios may not apply to all money transfer systems, such as money transfer by phone.

AGENT FRAUD PERPETRATED OVER THE TELEPHONEFraudsters will call the Agent location and try to induce an Associate to provide access to the Agent’s computer systems. Once they have access, fraudsters use the point-of-sale system to send money without the Agent location being able to collect funds for the transaction. They can also download or have the Associate unknowingly download harmful computer viruses. The Associate must be aware of the fraud types below to help the Agent to avoid being defrauded.

REMOTE ACCESSA fraudster calls an Agent location posing as Western Union or network technical services claiming that the Western Union system needs to be updated/upgraded. The Agent employee agrees to establish a personal computer support connection using remote access software. The Fraudster may then take control of

the personal computer and send transactions without funds being collected by the Agent location.

COMPUTER INTRUSIONSAn Agent employee clicks a link in an e-mail or visits a website and unknowingly downloads malicious software onto the computer offering Western Union services. This malicious software, through key loggers, captures Western Union Operator identification documents and passwords, which may be used later by fraudsters to send transactions.

TEST TRANSACTIONSA fraudster calls an Agent location to have the Agent Associate enter transaction data as a test or training session which ultimately results in a transaction being sent without funds being collected.

CODE ENTRIESA fraudster calls an Agent location and instructs the Agent Associate to enter codes into the Western Union system to fix a technical issue or update the point-of-sale system. When the Agent Associate follows the fraudster’s instructions, by entering a 16-digit card number and 5-digit dollar amount, the effect is to re-load a prepaid card that belongs to the fraudster.

AGENT FRAUD PERPETRATED BY E-MAILE-mail fraud (also called Phishing) is designed to get the Associate or any other Agent employee to unknowingly provide the fraudster access to the Agent’s internal computer systems. Phishing can also be done over a mobile phone or text. This fraud scheme is designed to steal personal information or to push malicious code or software onto the Agent’s computer or mobile phone. All Associates who have access to the Agent’s computers must be trained on how to avoid being the victim of phishing.

Below are indicators that the Associate can look for to help identify a potential phishing e-mail:

• an unknown sender

• an unsolicited correspondence

• an unexpected correspondence

• generic greetings

• requests for personal information

• a sense of urgency, and

• poor grammar or spelling



If the Associate thinks they may be reading a phishing message, the Associate SHOULD:

• hover over any e-mail links to see the site the link is sending the user to

• delete all suspicious-looking e-mails

The employee SHOULD NOT do the following with a suspected phishing fraud:

• Click on links in e-mails that look suspicious. Simply clicking on a link can download harmful files onto your computer or mobile device.

• Provide your log on credentials or other sensitive personal information to anyone over the phone or e-mail. Doing so may give a cyber-criminal easy access to your online accounts or computer.

PROTECTING THE AGENT FROM FRAUDTo tighten security at your Agent location(s) and to help prevent your Agent location(s) from becoming a victim of fraud, never perform any of the following actions:

• NEVER send a money transfer transaction without first collecting funds.

• NEVER enter any information into the Western Union system based on a request from an incoming phone call.

• NEVER agree to a personal computer support connection unless you have previously initiated contact with Western Union or your corporate office regarding an issue with your personal computer, even if the caller states they are from Western Union or your network’s technical services.

• NEVER download software from an unknown source or insert a CD/USB (given to you) into the personal computer that is used to provide Western Union services.

• NEVER enter a “test” or “training” transaction into the live system. If using WUPOS™, verify system status in upper right corner of screen. Western Union will never perform a test in a live system.

• NEVER return or make a call to Western Union using a telephone number supplied by a caller. Only use numbers provided by Western Union in official company documents.

Take these technical actions to help protect the Agent location from fraud.

• Personal Computers with Western Union services should run industry supported software only and must be upgraded/patched in a timely manner when prompted. Ensure adequate anti-virus, anti-spyware and firewall programs — set an auto-update/auto-run for daily protection.

• Do not run non-company email or other software on a personal computer used to process WU transactions.

• Disable USB ports, floppy disks and CDROMs on personal computers used to provide Western Union services.

• Set designated hours of operation in the Western Union system so that the money transfer system is not active after normal business hours. Shut down the personal computer after the location’s hours of operation.

• Employees should lock personal computers when leaving their work stations.

• Delete all Operator identification documents for any resigned or former Associates.

• Operator identification documents and passwords should never be shared with anyone, including other employees or anyone requesting passwords over e-mail or text. System passwords should be changed every 90 days.



EVERYDAY FRAUD PREVENTION PRACTICESThere are common practices that the Agent must implement that will assist in preventing fraud against consumers and against the Agent. These include:

• reviewing the Fraud Awareness education materials that WU has provided to your location

• promptly reviewing any fraud alerts from Western Union that are posted on the money transfer system or in Agent Portal (these messages contain timely fraud alert information)

• never allow consumers to see the personal computer screen when the Associate is entering transaction or consumer information into the system

• never allow unauthorized persons access behind the counter or near the Western Union transaction area; and

• never respond to e-mails, phone calls or faxes requesting Western Union account information, such as account numbers, terminal IDs, operator identification documents and passwords. Western Union will never call an Agent and ask for this information. Do not respond if anyone calls you and asks for system access, passwords, or other security protocols.

IMPORTANT NOTE: Western Union will never contact an Agent Location or Associate to instruct the Agent to complete transactions on the system without obtaining payment, for any reason� System tests are never performed in live system mode� Any such communication you receive is likely an attempt to defraud you and should be reported to Western Union immediately�



Section 5. Other Required Compliance Program ComponentsThis section describes additional Agent Compliance Program components that must be incorporated into your compliance program.

PROHIBITION AGAINST SENDING OR RECEIVING TELEMARKETING TRANSACTIONSThe United States Federal Trade Commission (“FTC”) amended its Telemarketing Sales Rule (“TSR”), effective June 13, 2016. The new rules ban sellers and telemarketers from accepting cash-to-cash money transfers or funds loaded onto a prepaid card from U.S. consumers as payment for goods or services offered or sold through telemarketing. Western Union and its Agents may also violate the TSR by facilitating the transfer of funds to a telemarketer, at least where they know, or consciously avoid knowing, that the seller or telemarketer is violating the rule.

The TSR defines “telemarketing” broadly to cover almost any commercial transaction that involves the use of a telephone to place or receive calls between a consumer located in one state to a telemarketer or seller in another state or country. For example, Western Union or a Western Union Agent location could violate the rule by transferring funds from a U.S. consumer to a telemarketer or seller relating to a promotion for a “free” or heavily discounted vacation, prize or sweepstakes scams, or the sale of “bargain” magazines. If the Associate suspects that the consumer may be sending funds to a telemarketer, or that the receiver of funds might be a telemarketer, the Agent should stop the transaction and report the event to the Agent’s Western Union Compliance Contact.

United States law and Western Union policy prohibits the use of Western Union products, services, and systems as a form of payment by sellers or telemarketers. Agents must assist WU in identifying, preventing and stopping the use of our products and services for telemarketing activities by:

• asking all consumers whether the transaction is a payment for goods or services offered through telemarketing

• declining to process known or suspected telemarketing transactions, and

• reporting suspected or known sellers and telemarketers to Western Union so that they may be interdicted.



DATA PROTECTION AND PRIVACYIt is the WU policy, and a requirement of various data privacy and protection laws globally, to protect the privacy of our consumers and their data. Consumers use WU to send and receive hard-earned money and they want to be sure they are using trustworthy and reputable Agents to do this. Ensuring that every consumer’s personal information is protected and secure is extremely important. You can protect consumers’ personal information and secure their data by doing the following:

• ensuring that only authorized staff at your location have access to the WU terminal and consumer forms, records and information

• ensuring that all consumer forms are kept organized in date order and that they are not left in the open for others to see

• shredding forms or any documents containing consumer, transaction, or Associate identification information after the mandated retention period ends

• maintaining stored consumer records in a secure location, which can include forms, SARs/STRs, monitoring information, consumer data, Sub-Agent, and Associate records

• keeping Agent-owned computers, systems and other equipment updated with reasonable firewalls, anti-virus software and other electronic controls to protect access to the Agent, WU systems, and the Agent’s records and documents.

RECORD KEEPING AND RECORD RETENTIONAll transaction forms, and compliance records related to Western Union products and services that are created or handled by the Agent must be retained for the longer of either (i) the legally required number of years from the date of the transaction in the jurisdiction where the Agent operates; or (ii) for five (5) years. Agent records must be retained in a manner and format consistent with local law, and within those parameters, in a manner that will allow them to be produced within required timeframes upon proper request by governmental, regulatory, judicial, or law enforcement agencies.

When in doubt, Agents should confirm the applicable legal retention periods with their Designated WU Compliance Contact, or contact the WU Records Management department at [email protected].

ASSOCIATE IDENTIFICATION RECORDSThe Agent compliance program must establish policies and procedures for collecting, and maintaining records regarding the identities of Agent and any Sub-Agent Associates using reliable, independent source documents, data, or information such as a government-issued or other acceptable identification document in your country, and safeguarding of the same. When determining the degree of reliability and independence of source documents, the Agent should consider the potential risks of fraud and counterfeiting in the country. In all cases the Agent must review the identification document to ensure that it is unexpired, and that the photo on the document, if there is one, resembles the Associate. Agents must also ensure that an Associate does not have a family relationship with an owner, manager, or Associate who has been suspended or terminated as an Agent for fraud related reasons. The Agent must maintain records for its own Associates (and Sub-Agent Associates) and make those records available to WU, subject to local legal prohibitions or restrictions.

LAW ENFORCEMENT REQUESTSWestern Union periodically receives requests from law enforcement agencies. It is the WU policy to fully cooperate with law enforcement requests and to provide whatever is appropriate for production. If you or one of your employees receives such a request, you must immediately inform your WU Compliance Contact.

A set of frequently asked Questions is attached as Appendix A� Please call your Western Union Compliance Contact if you have any questions about the information in this Manual�

mailto:wurecordsmanagement%40westernunion.com?subject=



Appendix A. Frequently Asked Questions ASSOCIATE TRAINING

Q. I have a new staff member starting soon – may I get them started processing Western Union transactions and then get an identification document on the system and the initial training completed?

A. No, this is not allowed. For training purposes, the Western Union system can be switched to training mode to allow practice transactions and to allow the new staff member to become familiar with the system. Before the new staff member conducts a live transaction for a consumer they must have their own unique Western Union system identification, and have completed Western Union training, including AML, CFT, consumer fraud, and consumer protection training. The training event for the staff member must be documented.

Q. I have some new staff members starting soon. We are almost ready for our annual ongoing training. Can we just wait and do it all together?

A. No, this will not meet the standards of the Agent Compliance Program. Initial training must be completed for the new staff members before they may offer Western Union products and services.

Q. A staff member recently left; may I destroy the training records I have for them?

A. No, you must retain the training records for at least five years from the training event. This is so that training can be confirmed for the time that the staff member was authorized to conduct transactions.

Q. Do I need to keep the quizzes that my staff members complete after I put the information on the training log?

A. Yes, you must maintain the satisfactorily completed quizzes for at least five years, as evidence that each Associate received a passing mark. The dates and names on the quizzes should match the entries on the training log.

Q. I am part of a larger, centralized network and we would like to design our own training. Is that allowed?

A. Yes, that is allowed. The training program must cover topics outlined in this Manual and otherwise required by the Agent Compliance Program or other WU policies or procedures, as well as any laws in your country. Each training must include a documented method of assessment, such as a written quiz. In addition, the training must be documented and made available for WU review. WU Compliance can provide guidance if you would like to develop a comprehensive training program. Please reach out to your WU Compliance Contact.

Q. What happens if I don’t meet the training requirement?

A. Training is one of the core elements of the Agent Compliance Program, and WU will assess the Agent’s completion of training throughout the life of the relationship. Deficiencies in this area may result in one or more of your locations being placed on probation or suspension until the issue is rectified and may result in suspension or termination of your ability to be a WU Agent.



THE ROLE OF THE COMPLIANCE OFFICER

Q. I am a sole proprietor; may I also act as the Agent CO?

A. Yes, if necessary. While it is not best practice, the owner/operator may assume both roles if there is not another person in your company who can be entrusted with this responsibility or is not qualified to be the Agent CO. The Agent Compliance Program must include procedures and controls to ensure that compliance responsibilities are appropriately implemented.

Q. I am the Agent CO, and now wish to designate another responsible employee to take over the Agent CO function. May I do this?

A. Yes. The Agent must notify your Designated WU Compliance Contact of the change and provide any required supporting documentation so WU can update our records. The change will not take effect until the new designate is trained by WU. The Agent may appoint a temporary Agent CO if the Agent CO is, or will be, absent for an extended period to ensure Agent Compliance Program standards are being met. This temporary change does not disengage the Agent CO from being responsible for the overall compliance of the Agent.

Q. My location is part of a bigger network; will you contact me directly to arrange reviews or gather information?

A. Each Agent operates in a different manner so this determination is made at the Agent’s head office and communicated out to the locations. In many instances, WU will contact the primary Agent CO who will assist WU in preparing for reviews and advising the locations that WU is coming to perform our reviews.

Q. I am the Agent CO for a centralized network. How am I supposed to identify patterns of activity across multiple locations?

A. Western Union has developed tools accessible online, that will allow you to review transactions across your network to identify suspicious patterns of activity. Please contact your WU Compliance Contact for more information, or if you need assistance accessing these tools.

Q. What happens if I don’t have a designated Agent CO?

A. Designation of a qualified Agent CO is one of the core requirements of the Agent Compliance Program, and WU will evaluate the Agent’s compliance with this obligation during the life of the relationship.



Appendix B. The Model Western Union Agent Fraud Policy and Procedures The model Fraud Policy and Procedure is attached. If you do not have your own anti-fraud policies and procedures document, you may adopt this model as your own. If you have your own anti-fraud policies and procedures document, you are required to review the standards in this Manual and the model Fraud Policy and Procedure and to ensure that your program meets the requirements in the model. Please contact your Designated WU Compliance Contact if you have any questions.

Appendix C. Money Laundering, Terrorist Financing, Human Trafficking, and Illegal Gambling Red FlagsMONEY LAUNDERING AND TERRORIST FINANCING RED FLAGSYou and your Associate should be alert to the following suspicious behaviors and activities that could indicate money laundering, terrorist financing, or the crimes that precede these transactions:

• Transactions made in multiple, small dollar amounts, indicating that the individual is trying to avoid monitoring systems or transaction reporting rules

• Consumer receives a payment and then sends most or all the amount in separate transactions within a short amount of time (“flipping”). Flipping is used primarily to avoid law enforcement monitoring

• Groups of individuals conducting transactions at single or multiple outlet locations or across multiple services

• Sender knows little or is reluctant to disclose details about the receiver (address or contact information, for example)

• Consumer inexplicably travels great distances to an Agent to conduct transactions

• Consumer has no apparent ties to the country where the funds are being sent or collected



• Consumer has been the subject of a law enforcement inquiry known by the Agent

• Consumer offers false identification, whether evident from the identification document or from the document’s context with other documents (e.g., use of two or more identification cards that are issued from different countries)

• Consumer shows different identification documents or different identification document information (such as phone or address) when coming to your location over time

• Consumer appears to be acting on behalf of a third party, but is not disclosing that information to the Associate, or seems to be nervous or under duress

HUMAN TRAFFICKING AND HUMAN SMUGGLING RED FLAGSHuman trafficking and human smuggling are serious crimes. Western Union is committed to preventing its products and services from being used to facilitate human trafficking and human smuggling. The Associate should be alert to potential human trafficking or human smuggling if they observe the behaviors listed below.

• Consumer behaves like they are being controlled by someone

• Someone else speaks for consumer, but puts the transaction in the consumer’s name. (This may be done to avoid identifying the true sender or receiver of funds.)

• Consumer does not hold their own identification card; someone else holds it for them. This may indicate coercion.

• Consumer has bruises, appears malnourished, or has other signs of physical abuse

• Consumer picks up a money transfer and immediately hands the funds to someone else

• Consumer brings in a completed money transfer form in someone else’s handwriting

• Consumer does not speak the local language

• Consumer cannot give their name or address without reading from a form

• Consumer seems to lack knowledge of their whereabouts or what city they are in

• Consumer appears fearful, anxious, depressed, submissive, tense, nervous, paranoid, or avoids eye contact

• Multiple smaller dollar amount transactions sent within a short time frame by multiple senders to a common receiver

• Consumer cannot confirm the name of payees they are sending a high value transaction to

• Consumer appears to have no familial or other close relationship with the person to whom they are sending money

• Consumer does not know the name of the person who sent them the money

ILLEGAL GAMBLING RED FLAGS The following are indications that the consumer may be using WU to fund illegal gambling:

• Consumer indicates to the Associate that a transaction is for gambling purposes

• Consumer might mention the game (such as Poker, Blackjack, or Bingo), or they may use phrases like: “this is for my losses,” “the odds were against me,” “playing cards,” or “for the horses”

• Consumer has an e-mail address containing gambling references



Appendix D. Consumer Fraud Red FlagsCONSUMER SENDING A POTENTIALLY FRAUD-INDUCED TRANSACTIONThe following are consumer behaviors the Associate should be aware of so they can help identify a potential fraud victim and ask the consumer additional questions about the transaction:

• A consumer explains that they are sending money for an internet purchase, employment opportunity, lottery or prize, rental property, fees for a loan or credit card, unconfirmed emergency or to someone they have not met in person.

• A consumer sends multiple transactions in a single day or over the course of a few days.

• A consumer is sending money for the first time and asks questions about the process.

• A consumer seems apprehensive or confused, especially elder and dependent adults.

• A consumer who wishes to delay the payment of funds.

• A consumer who wishes to use a test question to safeguard their funds.

• A consumer who appears to be following written instructions for how to transfer money.

If the Associate suspects a sender is about to become a victim of a fraud scam they should do one or more of the following:

• Ask questions about the transaction in a friendly, nonthreatening manner, for example,

� “Have you met the receiver in person?”

� If sending for an emergency situation, “Have you verified the emergency with a friend or family member who would have knowledge of the situation?”

� “Did the seller give you an option to pay on-line or do they only allow payment using a money transfer service like WU?”

• Tell the consumer that similar types of transactions have been associated with fraud and that they should think about not sending the money.

• Reject the transaction if you suspect that the consumer is a victim of fraud, even if the consumer insists on sending it. If the Associate sends a transaction that they suspect may related to consumer fraud, or if the Associate receives complaints or concerns about known or suspected fraud, you must call the Western Union Fraud Hotline or your WU Compliance Contact for assistance.



CONSUMER RECEIVING A POTENTIALLY FRAUD-INDUCED TRANSACTIONAlways follow proper payout procedures, confirming that the information provided by the consumer matches what is recorded in the system: MTCN, amount, expected payout area location, originating country and sender’s name. The consumer’s receiver identification must also match what is in the system and must be current (i.e., not expired), government issued, show no signs of being altered and contain the consumer’s first name, last name and a photograph of the consumer. Scrutiny should always be given to the receiver’s identification to verify its authenticity.

Below are examples of potential consumer fraud red flags that an Associate can look and listen for to help identify a consumer who may be receiving fraud-induced transactions. Note that these lists are not exhaustive, and you should consider any out-of-the-ordinary behavior or transaction patterns as a potential indicator of consumer fraud.

POTENTIAL BEHAVIORAL RED FLAGS FOR FRAUD:• The consumer exhibits suspicious behavior, such as

loitering or nervousness, failing to make eye contact, checking phone for directives, scoping out the area.

• Multiple individuals enter a location but only one person transacts. (Often the others will loiter near the door.)

• The consumer appears confused, is unfamiliar with how to use Western Union, or is following the directions of someone on their phone as they pick up the transfer.

• The receiver admits they have never met the sender or appears coached to state that they have met the sender.

POTENTIAL TRANSACTION-RELATED RED FLAGS:• Consumers who receive multiple transactions under

different names or spelling variations

• Consumers who receive multiple transactions from different senders in similar or nonstandard dollar amounts in a short amount of time.

• Consumers who receive an unusual number of transactions in a short period of time.

• Consumers who receive multiple transactions to one receiver with the use of a security question.

• Consumers who receive transactions from multiple senders with no apparent family relationship.

• Consumers who receive transactions from multiple states, provinces or countries.

• Consumers who frequently both receive and send transactions by one person, especially when transactions are sent to other countries, when the amount received matches the amount being sent, and when consumers who receive transactions immediately attempt to send transactions.

AGENTREFERENCE

AGENT ANTI-FRAUD POLICY AND PROCEDURES

EBKENCPPE

Agent Anti-Fraud Policy and Procedures2 WESTERN UNION © 2017 Western Union Holdings, Inc. All Rights Reserved. CONFIDENTIAL. Rev. 07/2017

Table of Contents1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2. PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3. CONSUMER FRAUD SCAM TYPES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

4. FRONT LINE ASSOCIATE RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . 74�1 Consumer Behavior Fraud Indicators – Send Side � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

4�2 Transaction Fraud Indicators – Send Side � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

4�3 Consumer Behavior Fraud Indicators – Pay Side � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

4�4 Transaction Fraud Indicators – Pay Side � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8

5. PROHIBITED TELEMARKETING TRANSACTIONS . . . . . . . . . . . . . . . . . . . . . . . 8

6. WHAT TO DO WHEN FRAUD IS SUSPECTED . . . . . . . . . . . . . . . . . . . . . . . . . . . 96�1 Talking to the Consumer � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

6�2 Following Proper Payout Procedures � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 10

7. FLA SAFETY CONCERNS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

8. PROTECTING AGAINST AGENT VICTIM FRAUD . . . . . . . . . . . . . . . . . . . . . . . . 118�1 Agent Fraud Perpetrated over the Telephone � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 11

8�2 Agent Fraud Perpetrated by E-mail � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 11

8�3 How to Protect the Agent from Fraud � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 12

9. EVERYDAY FRAUD PREVENTION PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . 12

If an Agent has questions about any of the information in this document, please contact your Dedicated Western Union Contact. The WESTERN UNION name, logo and related trademarks and service marks, owned by Western Union Holdings, Inc., are registered or used in the U.S. and many foreign countries. THE INFORMATION CONTAINED IN THIS MATERIAL IS CONFIDENTIAL AND PROPRIETARY TO WESTERN UNION. ANY USE, COPYING, OR REPRODUCTION OF THIS MATERIAL WITHOUT THE PRIOR WRITTEN PERMISSION OF WESTERN UNION IS STRICTLY PROHIBITED. Western Union Holdings, Inc. All Rights Reserved.

NAME OF BUSINESS

ADDRESS

CITY, COUNTRY, MAIL CODE

DATE


Agent Anti-Fraud Policy and Procedures

1. IntroductionThis Policy and Procedure (“P&P”) describes the program standards that Western Union (“WU”) requires its Agents1 to implement, and describes steps the Agent should take to adopt these requirements. The standards and requirements established in this P&P are part of the Western Union Service Requirements. Western Union is available to assist Agents if there are any questions about the program requirements in this P&P.

This P&P has been adopted by the Western Union Agent named at the top of the page. The purpose of this P&P is to establish an anti-fraud program designed to protect Western Union consumers. Consumer fraud is committed by people who perpetrate scams by convincing unwary individuals to send them money. Various types of scams are described throughout this P&P. All front-line associates (“FLAs”) must read this P&P and understand the scam types listed in this P&P. (An FLA is an individual who executes Western Union transactions at the Agent location.) All FLAs must complete fraud training prior to providing Western Union products and services. This P&P describes the steps an FLA must take if the Agent or a consumer appear to be the victim of a fraud.

Due to advances in technology, methods of defrauding well-meaning consumers are becoming more sophisticated and diffi cult to detect. Because of this, Western Union Agents can unknowingly be used to help criminals defraud people. The processes required in this P&P are designed to detect and deter criminals from using Western Union products and services to defraud consumers. Agent and FLA awareness of consumer behavior and transaction types at the point of sale can help deter fraud against Western Union consumers.

This P&P also implements processes designed to prevent Agents from becoming victims of fraud as well. Agent Victim Fraud is an action by a third-party that results in a fi nancial loss to an Agent or to Western Union. Agent FLAs play an important role in protecting the Agent from falling victim to fraud. All FLAs that process Western Union transactions must read this P&P and complete training on how to detect, prevent, and report Agent Victim Fraud.

1 An “Agent” in this Manual refers to any Master Agent, Network Agent, Authorized Delegate, or Independent Agent with which Western Union has an established contractual relationship to sell or provide Western Union products or services to consumers. Sub-Agents operating under a contract signed by a Master Agent or their parent company are also required to follow this policy. Agents include those transacting under the Western Union, Orlandi Valuta, and Vigo brands.

Fraud prevention is a partnership between the Agent and Western Union. For these reasons, this P&P requires FLA training and awareness, as well as healthy communication between the Agent and Western Union through the Agent’s Dedicated Western Union Contact. Western Union is required by their regulators to monitor fraud activity at all Agent locations and to suspend or terminate Agents (or their locations) that are being used to facilitate fraud transactions. If an FLA is complicit in the fraud, Western Union will terminate the Agent’s ability to provide Western Union products and services at the Agent’s location. In instances where a fl oating FLA is complicit in fraud activity, Western Union will terminate the Agent’s ability to provide Western Union products and services at any location where the fl oating FLA committed the complicit activity and terminate the fl oating FLA’s ID. It is therefore critical that all FLAs understand the principles in this P&P and follow the procedures outlined here.

The Agent’s designated offi cer identifi ed in the box below is responsible for ensuring that this P&P and all appropriate training has been implemented.

RESPONSIBLE OFFICER

FULL NAME

ADDRESS

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2. PurposeThe purpose of this P&P is to establish the fraud prevention measures and processes that all Western Union Agents are required to implement. This P&P provides descriptions of different fraud and transaction types that have been used in the past to defraud Western Union consumers and Agents. It also describes consumer behaviors which indicate that a consumer may be a victim of fraud or other crime. All FLAs should observe consumer behavior as part of the money transfer process, and be able to identify consumers exhibiting these behaviors. This P&P also describes situations that may indicate that the Agent is being targeted as a victim of fraud. Training and awareness are the foundation of this fraud program.



3. Consumer Fraud Scam Types The following is a list of consumer fraud scams that have been observed. Please note that this list provides examples of fraud scams that have been observed, but may not include all potential fraud scams. All FLAs must be able to recognize these scams so they can be on alert when a consumer acts or makes statements that indicate they are a potential victim of a fraud. Criminal methods for defrauding consumers evolve over time, so from time to time this list may be updated. The Agent’s Dedicated Western Union Contact is available to provide assistance if the Agent has questions about these scenarios.

ADVANCED FEE OR PREPAYMENT SCAMVictim is asked to pay upfront fees for fi nancial services which are never provided. Victims often send a succession of transactions for payment of various upfront fees. Methods: credit card, grant, loan, inheritance, investment.

ANTI-VIRUS SCAMVictim is contacted by someone claiming they are from a well-known computer or software company and a virus has been detected on the victim’s computer. The victim is advised that the virus can be removed and the computer protected for a small fee with a payment by either credit card or a money transfer. In reality, there was no virus on the computer and the victim has just lost the money they sent for the protection.

CHARITY SCAMThe victim is often contacted by email, mail or phone by someone asking for a donation to be sent by money transfer to an individual to help victims of a recent current event, such as a disaster or emergency (such as a fl ood, cyclone, or earthquake). Legitimate charity organizations will never ask for donations to be sent to an individual through a money transfer service.

EMERGENCY SCAMVictim is led to believe that they are sending funds to assist a friend or loved one in urgent need. Victim sends the money with urgency as the victim’s natural concern for a loved one is exploited.

EMPLOYMENT SCAMVictim responds to a job posting and is hired for the fi ctitious job and sent a fake cheque for job related expenses. Cheque amount exceeds the victim’s expenses and victim sends remaining funds back using a money transfer. The cheque bounces and the victim is responsible for the full amount.

FAKE (COUNTERFEIT) CHEQUES SCAMVictims are often sent a cheque as a part of a scam and told to deposit the cheque and use the funds for employment expenses, internet purchases, mystery shopping, etc. The cheque is fake (counterfeit), and the victim is left responsible for any funds used from the cheque. Remember, funds from a cheque deposited into an account should not be used until the cheque offi cially clears which can take weeks.

GRANDPARENT SCAMThis scam is a variation on the Emergency Scam. The victim is contacted by an individual pretending to be a grandchild in distress, or a person of authority such as a medical professional, law enforcement offi cer, or attorney. The fraudster describes an urgent situation or emergency (bail, medical expenses, emergency travel funds) involving the grandchild that requires a money transfer to be sent immediately. No emergency has occurred, and the victim who sent money to help their grandchild has lost their money.

IMMIGRATION SCAMVictim receives a call from someone claiming to be an immigration offi cial saying there is a problem with the victim’s immigration record. Personal information and sensitive details related to the victim’s immigration status may be provided to make the story seem more legitimate. Immediate payment is demanded to fi x any issues with the victim’s record and deportation or imprisonment may be threatened if payment is not made immediately by money transfer.

INTERNET PURCHASE SCAMThe victim sends money for the purchase of item ordered online (e.g. pets, cars). Items are often advertised on Craigslist, eBay, Alibaba, etc. After the money is sent, the victim never receives the merchandise.



TAX SCAMVictim is contacted by someone claiming to be from a governmental agency saying that money is owed for taxes, and it must be paid immediately to avoid arrest, deportation or suspension of driver’s license/passport. The victim is instructed to send a money transfer or purchase a pre-loaded debit card to pay the taxes. Government agencies will never demand immediate payment or call about taxes without fi rst having mailed a bill.

LOTTERY OR OTHER PRIZE SCAMVictim is told that they have won a lottery, prize or sweepstakes and that money must be sent to cover the taxes or fees on the winnings. The victim may receive a cheque for part of the winnings and once the cheque is deposited and money is sent, the cheque bounces.

MYSTERY SHOPPING SCAMThe fraudster contacts the victim through an employment website, or the victim responds to an ad about an employment opportunity to evaluate a money transfer service. The fraudster often sends the victim a cheque to deposit and instructs the victim to send a money transfer, keeping a portion of the cheque for their pay. The victim sends the money, the fraudster picks it up, and when the cheque bounces the victim is left responsible for the full amount.

OVERPAYMENT SCAMThe fraudster sends the victim a cheque that appears to be valid as payment for a service or product. Typically, the amount of the cheque exceeds what the victim expects to receive, and the fraudster tells the victim to send the excess back using a money transfer. When the cheque bounces, the victim is left responsible for the full amount.

RELATIONSHIP SCAMVictim is led to believe that they have a personal relationship with someone they met online often by social media, in an online forum or on a dating website. The victim is often emotionally invested, often referring to the recipient as a fi ancée.

RENTAL PROPERTY SCAMVictim sends money for deposit on a rental property and never receives access to the rental property or the victim may also be the property owner who is sent a cheque from the renter and asked to send a portion of the cheque back using a money transfer and the cheque bounces.



4. Front Line Associate ResponsibilitiesFront Line Associates must be trained prior to conducting Western Union transactions to help identify the types of fraud schemes, transactions, and consumer behavior that indicate a consumer may be a victim of fraud. If the consumer’s answers, behavior or transaction patterns indicate that they may be a victim of fraud, the FLA can refuse to send the transaction.2

2 If there are requirements to report a transaction that was refused because the FLA suspected fraud, the FLA must follow the specifi c reporting requirements.

4.1 CONSUMER BEHAVIOR FRAUD INDICATORS – SEND SIDE

4.2 TRANSACTION FRAUD INDICATORS – SEND SIDE

4.3 CONSUMER BEHAVIOR FRAUD INDICATORS – PAY SIDE

All FLAs are responsible for understanding the consumer behaviors described below. Western Union is providing typical consumer behaviors for sending transactions which may indicate that a consumer is a victim of fraud. The following are consumer behaviors the FLA should be aware of so they can help identify a potential fraud victim and ask the consumer additional questions about the transaction.

� Consumers who may seem apprehensive or confused, especially elderly and dependent adults.

� Consumers who seem overly excited to send money.

� Consumers who express concern about sending money for an emergency.

� Consumers who seem excited or anxious about receiving a large sum of money or “once-in-a-lifetime deal.”

� Consumers who say they are buying something that they were sold over the phone. Western Union Agents may not process a cash or pre-paid card payment that is the result of a telemarketing call. See Prohibited Telemarketing Transactions below.

� Consumers who may be sending money for the fi rst time and ask questions about the process.

NOTE: All elder and dependent adult consumers should be asked if they have met the person they are sending money to because they are highly vulnerable to telephone or online fraud�

The FLA should be aware of the following scenarios, and ask the consumer additional questions about the transaction, because they may be evidence of a fraud or other crimes.

� Consumers who send multiple transactions in a single day or over the course of a few days.

� Consumers who wish to protect or delay their money transfer by using a test question.

� Consumers who are sending to himself/herself and later changes the recipient of the transaction.

The following behaviors are examples of indications that a consumer may be picking up a fraudulently-induced transaction at the Agent’s location:

� Consumers exhibiting suspicious behavior, such as loitering or nervousness, failing to make eye contact, checking phone for directives, scoping out the area.

� Multiple individuals entering location and only one person transacting (often the others will loiter near the door).

� Consumers who appear confused, are unfamiliar with how to use Western Union® or who are following the directions of someone on their phone as they receive the transfer.

� Consumers who admit they have never met the sender or appear to have been coached to state that they have met the sender.

� Consumers who are following the direction of someone on their phone or standing outside of the location as they receive a transaction.



4.4 TRANSACTION FRAUD INDICATORS – PAY SIDE

The FLA should be aware of the following examples of types of transactions, and ask the consumer additional questions about the transaction, because they may be evidence of a fraud or other crimes.

� Consumers who receive transactions under different names or spelling variations.

� Consumers who receive non-standard or unusual transaction amounts in a short period of time.

� Consumers who receive an unusually high number of transactions in a short period of time.

� Consumers who receive multiple transactions requiring a security question.

� Consumers who receive multiple transactions from multiple senders with no apparent family relationship.

� Consumers who receive multiple transactions from several different states, provinces or countries.

� Consumers who frequently both receive and send transactions, especially when transactions are sent outside the Agent’s country, when the amount sent matches the amount being paid out. Pay close attention to when a payout consumer immediately attempts to send the received funds to another person.

� A consumer who picks up cash and then visibly hands the cash to another person either inside or outside of the Agent location.

5. Prohibited Telemarketing TransactionsThe United States Federal Trade Commission (“FTC”) amended its Telemarketing Sales Rule (“TSR”), effective June 13, 2016. The new rules ban sellers and telemarketers from accepting cash-to-cash money transfers or funds loaded onto a prepaid card from U.S. consumers as payment for goods or services offered or sold through telemarketing. Western Union and its Agents may also violate the TSR by facilitating the transfer of funds to a telemarketer, at least where they know, or consciously avoid knowing, that the seller or telemarketer is violating the rule.

The TSR defi nes “telemarketing” broadly to cover almost any commercial transaction that involves the use of a telephone to place or receive calls between a consumer located in one state to a telemarketer or seller in another state or country. For example, Western Union or a Western Union Agent location could violate the rule by transferring funds from a U.S. consumer to a telemarketer or seller relating to a promotion for a “free” or heavily discounted vacation, prize or sweepstakes scams, or the sale of “bargain” magazines. If the Agent or FLA is suspicious that the consumer may be sending funds to a telemarketer, or that the receiver of funds might be a telemarketer, the Agent should stop the transaction and report the event to the Agent’s Dedicated Western Union Contact.



6. What to do When Fraud is SuspectedThere are steps that the FLA can take to prevent fraud against consumers at their location. Because the FLA is present when the consumer is sending fraud-induced funds, the FLA’s role in fraud prevention is essential. This section describes measures that the FLA can take at the time a fraud transaction is attempted, and as follow-up after the consumer or fraudster leaves the location.

6.1 TALKING TO THE CONSUMER

If the FLA has seen any of the behaviors or transaction indicators for sending consumers described in Consumer Behavior Fraud Indicators – Send Side or Transaction Fraud Indicators – Send Side, above, the FLA should:

� ask the consumer why they are sending money;

� ask the consumer if the person receiving the money is someone the consumer has met in person (face-to-face);

� if funds are being sent for an “emergency,” ask the consumer to verify that there is a true emergency before sending the money;

� educate the consumer by sharing this advice:

− “Never send money to someone you have not met in person.”

− “Never send money for an emergency unless you have fi rst verifi ed that there is an emergency.”

− “Never send funds that the consumer has received by cheque until the cheque has cleared, which can sometimes take weeks.”

� give the consumer the Western Union Fraud Awareness brochure (if available) and tell them to visit www.wu.com/fraudawareness;

� if the FLA suspects that a consumer is the victim of a fraud, tell the consumer you cannot send the money for the consumer’s own protection;

� advise the consumer that fraud is suspected, and they should verify that the transaction is being sent for a legitimate purpose;

� if you send a transaction that you think is in furtherance of a fraud, call the Western Union Fraud Hotline to suspend the transaction. Please contact your Dedicated Western Union Contact if you are unsure of the correct fraud hotline telephone number for your country;

� if a consumer comes to an Agent location to complain that they have been the victim of a fraud using Western Union branded products and services, the Agent should either call the Western Union fraud hotline to report the fraud, or instruct the consumer on how to call the fraud hotline. The Agent should also give the consumer fraud prevention information.

https://www.westernunion.com/fraudawareness



7. FLA Safety ConcernsIf the FLA is concerned for their safety, the FLA may send the funds, but must immediately contact Western Union to suspend any transaction that was sent. If the Agent location is equipped with the send side fraud hot key, they should queue the transaction to Western Union for review. Similarly, if the FLA is concerned for their personal safety on the pay side, they should pay the transaction. If the Agent location is equipped with the pay side fraud hotkey, they should queue the transaction to Western Union and inform the consumer that the transaction is unavailable.

6.2 FOLLOWING PROPER PAYOUT PROCEDURES

Front Line Associates must always follow proper payout procedures to make sure that information provided by the consumer matches what is recorded in the point of sale system. The FLA must check the following fi elds on the screen before paying out:

� the Money Transfer Control Number,

� the amount of the payout,

� the area (country, city, or town) where the payout is to be made,

� the country (location) the funds were sent from, and

� the sending consumer’s name.

In addition to this transaction information, the FLA must make sure that the payout consumer’s identifi cation matches what is in the point of sale system. The identifi cation provided by the consumer receiving funds must be:

� be current (not expired),

� be Acceptable under local AML rules in the country (for example, is a government-issued ID required?),

� be original and not altered, and

� contain the consumer’s fi rst and last name, plus a photograph of the consumer that matches the individual collecting the funds.

If the FLA suspects fraud, they should also ask open-ended questions that cause the payout consumer to think about their responses. (An open-ended question is one that cannot be answered with a simple “yes” or “no”.) The FLA should pay attention to the consumer’s answers to these questions and determine if the answers make sense. The FLA should also pay attention to the

consumer’s behavior, such as nervousness, or if they check their phone or written notes before answering. The FLA should choose questions that are appropriate for the situation and may use questions different from those provided below if they have worked well in the past. Examples of open-ended questions are:

� “How do you know the person who sent you the money?”

� “Where and when did you meet the sender?”

� “Why was this money sent to you?”

� “Do you use Western Union often?”

� “Were you asked by someone else to come to the Agent to pick up the money?”

If the FLA suspects fraud, it is recommended that the FLA ask the receiver for a second form of identifi cation. This second form of identifi cation should be a document that matches the name on the fi rst form of identifi cation, for example, a phone, water, or electricity bill. Requesting a second form of identifi cation may help the FLA prevent an individual from picking up a fraudulently induced transaction. This second form of identifi cation is for verifi cation purposes and does not need to be recorded.

Any transaction that an FLA suspects is related to fraud should not be paid out. The FLA should inform the consumer that the transaction is not available at that time. If the FLA does not payout the funds because the FLA suspects fraud, they should report the transaction to their Dedicated Western Union Contact. If the Agent is required to fi le Suspicious Transaction (or Activity) Reports, the Designated Compliance Offi cer should follow the country’s suspicious report fi ling rules and procedures.



8. Protecting Against Agent Victim FraudAgents and their locations can also be the victim of fraud. Agent victim fraud is fraud perpetrated against the Agent location that results in a fi nancial loss for the location. This P&P requires Agents to implement training and procedures for all employees to prevent fraud against the Agent. Fraud against Agents can happen in different ways. Below are common methods for defrauding Agents. Please note that these scenarios may not apply to all money transfer systems, such as money transfer by phone.

8.1 AGENT FRAUD PERPETRATED OVER THE TELEPHONE

8.2 AGENT FRAUD PERPETRATED BY E-MAIL

Fraudsters will call the Agent location and try to induce an FLA to provide access to the Agent’s computer systems. Once they have access, fraudsters use the point of sale system to send money without the Agent location being able to collect funds for the transaction. They can also download or have the FLA unknowingly download harmful computer viruses. The FLA must be aware of the fraud types below to help avoid being defrauded.

REMOTE ACCESSA fraudster calls an Agent location posing as Western Union or network technical services claiming that the Western Union system needs to be updated/upgraded. The Agent employee agrees to establish a PC support connection using remote access software. The Fraudster may then take control of the PC and send transactions without funds being collected by the Agent location.

COMPUTER INTRUSIONSAn Agent employee clicks a link in an email or visits a website and unknowingly downloads malicious software onto the computer offering Western Union services. This malicious software, through key loggers, captures Western Union Operator IDs and passwords, which may be used later by fraudsters to send transactions.

TEST TRANSACTIONSA fraudster calls an Agent location to have the Agent employee enter transaction data as a test or training session which ultimately results in a transaction being sent without funds being collected.

CODE ENTRIESA fraudster calls an Agent location and instructs the Agent employee to enter codes into the Western Union system to fi x a technical issue or update the point of sale system. When the Agent employee follows the fraudster’s instructions, by entering a 16-digit card number and 5-digit dollar amount, the effect is to re-load a prepaid card that belongs to the fraudster.

E-mail fraud (also called Phishing) is designed to get the FLA or any other Agent employee to unknowingly provide the fraudster access to the Agent’s internal computer systems. Phishing can also be done over a mobile phone or text. This fraud is designed to steal personal information or to push malicious code or software onto the Agent’s computer or mobile phone. All FLAs who have access to the Agent’s computers must be trained to avoid being the victim of phishing.

Below are indicators that the FLA can look for to help identify a potential phishing email:

� an unknown sender,

� an unsolicited correspondence,

� an unexpected correspondence,

� generic greetings,

� requests for personal information,

� a sense of urgency, and

� poor grammar or spelling.

If the FLA thinks they may be reading a phishing fraud, the FLA should:

� DO: Hover over any email links to see the site the link is sending the user to.

� DO: Delete all suspicious looking emails

The employee should NOT do the following with a suspected phishing fraud:

� DO NOT: Click on links in emails that look suspicious. Simply clicking on a link can download harmful fi les onto your computer or mobile device.

� NEVER: Provide your log on credentials or other sensitive personal information to anyone over the phone or email. Doing so may give a cyber-criminal easy access to your online accounts or computer.



9. Everyday Fraud Prevention PracticesThere are common practices that the Agent is required to implement that will assist in preventing fraud against consumers and against the Agent. These include:

� reviewing the Fraud Awareness education materials provided to your location by Western Union;

� reviewing any fraud alerts from Western Union posted on the money transfer system or in AgentPortal (these messages contain timely fraud alert information);

� never allowing consumers to see the PC screen when entering transaction information;

� never allowing unauthorized persons access behind the counter or near the Western Union transaction area; and

� never respond to emails, phone calls or faxes requesting Western Union account information, such as account numbers, terminal IDs, operator IDs and passwords. Western Union will never call an Agent and ask for this information. Do not respond if anyone calls the Agent and asks for system access, passwords, or other security protocols.

8.3 HOW TO PROTECT THE AGENT FROM FRAUD

To tighten security at your Agent location and to help prevent your Agent location from becoming a victim of fraud, NEVER perform any of the following actions:

� NEVER send a money transfer transaction without collecting funds.

� NEVER enter any information into the Western Union system based on an incoming phone call.

� NEVER agree to a PC support connection unless you have initiated contact with Western Union or your corporate offi ce regarding an issue with your PC, even if the caller states they are from Western Union or your network’s technical services.

� NEVER download software from an unknown source or insert a CD/USB provided to you into the PC providing Western Union services.

� NEVER enter a test/training transaction into the live system. If using WUPOS™, verify system status in upper right corner of screen.

� NEVER return or make a call to Western Union using a telephone number supplied by the caller. Only use numbers provided by Western Union in offi cial company documents.

Take these technical actions to protect the Agent location from fraud.

� PCs with Western Union services should run industry supported software only and must be upgraded/patched in a timely manner when prompted. Ensure adequate anti-virus, anti-spyware and fi rewall programs — set an auto-update/auto-run for daily protection.

� Do not run external email capabilities.

� Disable USB ports, fl oppy disks and CDROMs on PCs used to provide Western Union services.

� Set designated hours of operation in the Western Union system so that the money transfer system is not active after hours. Shut down the PC after the designated hours of operation.

� Employees should lock PCs when leaving their work stations.

� Delete the Operator IDs for any resigned or terminated employees.

� Operator IDs and passwords should never be shared with anyone, including other employees or anyone requesting passwords over email or text. Passwords should be changed every 90 days.

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