Common use of Agent Fraud Complicity Programs Clause in Contracts

Agent Fraud Complicity Programs. In January 2008, two Western Union departments separately proposed methods to discipline potentially Complicit Western Union Agent Locations. One proposal specifically warned against the influence of sales employees on any Agent location disciplinary process because sales employees’ “compensation is often based on agent performance—so they … see no reason good enough to hold their agent responsible” for fraud transactions. A Western Union senior vice president said she was “coordinating the many functions in the company that look at … data which might indicate an agent, a location, or an agent employee is engaged in illegal activities.” She was “focused on … analysis of the consumer fraud complaints … from a risk-based approach, separating out agent locations … that are complicit and need to be suspended.... [And] the need to enhance processes” at Western Union. Western Union’s then- Chief Compliance Officer wrote, “I am in favor of this proposal with two caveats: The necessary resource commitment - the more we look [for Agent involvement in fraud schemes] the more we find… and I’d like this communicated in the appropriate way so that everyone understands their roles and responsibilities.” Western Union did not implement either of the proposed disciplinary programs.

Agent Fraud Complicity Programs. In January 2008, two Western Union departments separately proposed methods to discipline potentially Complicit Western Union Agent Locations. One proposal specifically warned against the influence of sales employees on any Agent location disciplinary process because sales employees’ “compensation is often based on agent performance—so they … see no reason good enough to hold their agent responsible” for fraud transactions. A Western Union senior vice president said she was “coordinating the many functions in the company that look at … data which might indicate an agent, a location, or an agent employee is engaged in illegal activities.” She was “focused on … analysis of the consumer fraud complaints … from a risk-based approach, separating out agent locations … that are complicit and need to be suspended.... [And] the need to enhance processes” at Western Union. Western Union’s then- then-Chief Compliance Officer wrote, “I am in favor of this proposal with two caveats: The necessary resource commitment - the -the more we look [for Agent involvement in fraud schemes] the more we find… and I’d like this communicated in the appropriate way so that everyone understands their roles and responsibilities.” Western Union did not implement either of the proposed disciplinary programs.