Kidnapping, treasure hunts, insurgents shooting down airplanes — sounds like the Fall TV lineup. But no, it’s our October Insurance Update. And in honor of the month’s most treasured sporting event, the Fall Classic, we...more
On February 25, 2020, the Tenth Circuit Court of Appeals upheld the dismissal of shareholders’ securities-fraud class action against the Western Union Company (“Western Union”) and several of its current and former executive...more
OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities. OFAC is aggressively seeking out new targets for enforcement. OFAC continues to focus on Iran, Cuba, Venezuela and North Korea,...more
Busy Labor Day for me, how are you folks doing? TCPAland’s latest blockbuster settlement came with a lesson to attorneys on the importance of contemporaneous time entries–especially those hoping to recover millions of...more
A recent opinion from a district court in California serves as a reminder to creditors and debt collectors of the limited circumstances upon which convenience fees can be collected. ...more
In the first several months of 2017, we have seen significant anti-money laundering settlements and penalties in the money transmitting business arising from lax compliance programs, including the record-setting Western Union...more
This post discusses individual liability in AML/BSA enforcement, which is an area of increasing attention. Indeed, according to public statements by the government, individual liability is the focus of enhanced scrutiny...more
Last week, California became the 50th state to join the multistate settlement with Western Union over its alleged complicity in fraud-induced wire transfers. This followed Western Union’s $5 million agreement with 49 state...more
Earlier this year, in January 2017, Western Union entered into a Deferred Prosecution Agreement with the Justice Department and the FTC, and agreed to pay $586 in forfeiture to settle anti-money laundering and consumer fraud...more
On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more
At the end of January, Western Union agreed to pay the United States government $586 million to resolve allegations that it failed to maintain an effective anti-money laundering program under the Bank Secrecy Act and aided...more
The Western Union Company (“Western Union”) entered into a deferred prosecution agreement (“DPA”) on January 19th with the Department of Justice, based on alleged willful failures to maintain an effective AML program and the...more
Western Union is facing a $586-million settlement, after admitting to aiding criminals in money laundering and fraud. The global money services business, with headquarters in Englewood, Colorado, has entered into...more
Welcome to the Hogan Lovells Global Payments Newsletter. In this monthly publication we provide an overview of the most recent payments, regulatory and market developments from major jurisdictions around the world as well as...more
Many may not realize that the Money Transmitter Division of the California Department of Business Oversight licenses and regulates money transmitters. Money transmitters include issuers of payment instruments (money orders),...more
The Federal Trade Commission (FTC) issued an alert this week reminding businesses that the Telemarketing Sales Rule (TSR) amendments that went into effect in November of 2015, prohibit telemarketers from using three types of...more
The Obama Administration’s move to normalize relations with Cuba continues to spur commercial interest in the island. Despite the U.S. economic embargo on Cuba, regulatory changes announced by the U.S. Department of the...more
The class action has settled. There is a possibility that a portion of the settlement fund, if otherwise unclaimed, will ultimately revert to the defendant. Does this possibility give the defendant standing to object to class...more
Western Union will pay $8.5 million to settle alleged violations of the Telephone Consumer Protection Act (TCPA) when it sent consumers unsolicited text messages advertising an “opt-in” for receiving periodic automated...more