Compliance Requirements

February 26, 2018

Compliance Requirements

IRS regulations require the capture of identification, address, and social security number for the sender and payee of all money transfers of $3000 or more (including charges).

The sender identification screen automatically displays when the appropriate identification information has not been entered.

For send amounts of $1,000 or more

  • Sender’s ID type.

  • Sender’s ID number.

  • Issuing state or country.

For send amounts of $3,000 or more

  • Sender’s date of birth.

  • Sender’s occupation.

  • Sender’s Social Security number (if none, Alien ID number or passport number).

For send amounts of $7,500 or more

For send amounts of $10,000 or more  (CTR required for amounts $10,000.01 or more)

  • File a Currency Transaction Report (CTR).

On April 24, 2002, new legislation went into effect as a part of the USA PATRIOT Act of 2001.  As a result of this legislation, all Western Union Money Transfer® Agents must implement their own anti-money laundering compliance program.  Specifically, each Agent needs to designate a Compliance Officer and implement a compliance program that includes written policies and procedures, internal controls, an employee training program and an independent review process.

The Internal Revenue Service (IRS) is the agency of the federal government that monitors compliance with the Bank Secrecy Act.  Western Union Agents are required to file the following reports:

Currency Transaction Report

A Currency Transaction Report (CTR) must be completed for cash transactions aggregating to more than $10,000 by or on behalf of one person in one business day.

    • Western Union will file Currency Transaction Reports for Money Transfer Agents.

    • Agents are responsible for filing CTRs for money orders if they have sold money orders to one consumer in one business day where      the cash collected amounts to more than $10,000 (fees included).

It is Western Union policy to record certain transaction data at $1,000, and the Act requires additional record keeping at various levels for money transfer and money order services. (See the chart in the back of the MT Compliance and MO Compliance sections of the Western Union Agent Reference Guide.)

Each Agent employee conducting a money order or money transfer transaction must have and use his/her own ID code (Operator ID) each time a transaction is conducted.

Please refer to the Anti-Money Laundering Compliance Manuals in the MT Compliance and MO Compliance sections of the Western Union Agent Reference Guide.