What changed in this filing

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Item 1. Business

2021-02-19 compared with 2020-02-20 · 199 added, 158 removed, 253 unchanged (59% of the section changed)

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The Western Union ® brand is globally recognized and represents speed, reliability, trust and convenience.

As people move and travel around the world, they are able to use the services of our well-recognized brand to transfer funds.

Our Consumer-to-Consumer money transfer service enables people to send money around the world, usually within minutes.

As of December 31, 2019, our services were available through a global network of over 550,000 agent locations in more than 200 countries and territories, and through many Western Union branded websites in a growing number of countries and territories.

Our Consumer-to-Consumer money transfer service enables people to use our well-recognized brand to send money around the world, usually within minutes.

As of December 31, 2020, our global network included over 550,000 agent locations in more than 200 countries and territories and many Western Union branded or partner websites in a growing number of countries and territories.

Each location in our agent network is capable of facilitating a consumer’s use of one or more of our services, with the majority offering a Western Union branded service.

As of December 31, 2019, more than 70% of our locations had experienced money transfer activity in the previous 12 months.

As of December 31, 2020, more than 65% of our agent locations had conducted money transfer activity in the previous 12 months.

Our Business Solutions services facilitate payment and foreign exchange solutions, primarily cross-border, cross-currency transactions, for small and medium size enterprises and other organizations and individuals.

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Our segments are Consumer-to-Consumer and Business Solutions.

All businesses and other services that have not been classified in these segments are reported as Other, which primarily includes our cash-based and electronic-based bill payment services, which facilitate payments from consumers to businesses and other organizations.

All businesses and other services that have not been classified in these segments are reported as Other, which primarily includes our bill payment services, which facilitate payments from consumers to businesses and other organizations.

In May 2019, we sold a substantial majority of our United States based electronic bill payments services, as discussed below.

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Business Solutions

No individual country outside the United States accounted for more than 7% of our consolidated revenue for each of the years ended December 31, 2019, 2018, and 2017.

No individual country or territory outside the United States accounted for more than 7% of our consolidated revenue for each of the years ended December 31, 2020, 2019, and 2018.

See Part I, Item 1A, Risk Factors, for a discussion of certain risks relating to our foreign operations.

Consumer-to-Consumer Segment

Individual money transfers from one consumer to another are the core of our business, representing 83% of our total consolidated revenues for 2019.

Money transfers from one consumer to another are the core of our business, representing 87% of our total consolidated revenues for 2020.

A substantial majority of these transfers were cross-border transactions.

Our money transfer service, including our online money transfer transactions conducted and funded through Western Union branded websites and mobile apps (“westernunion.com”), is provided through one interconnected global network where a money transfer can be sent from one location to another, around the world.

Although most remittances are sent from one of our agent locations worldwide, in some countries and territories we offer the ability to initiate transactions from a Western Union branded website.

Our money transfer service is mainly conducted through our retail agent locations worldwide but also includes our fast-growing money transfer transactions conducted and funded through websites and mobile applications marketed under our brands (“westernunion.com”) and transactions initiated on internet and mobile applications hosted by our third-party white label or co-branded digital partners (together with westernunion.com, “Digital Money Transfer”).

This segment includes five geographic regions whose functions are primarily related to generating, managing, and maintaining agent relationships and localized marketing activities.

westernunion.com is included in these regions.

By means of common processes and systems, these regions, including westernunion.com, create an interconnected network for consumer transactions, thereby constituting one global Consumer-to-Consumer money transfer business and one operating segment.

We include Digital Money Transfer transactions in these regions, including transactions from our arrangements with financial institutions and other third parties to enable such entities to offer money transfer services to their own customers under their brands, as further discussed below.

By means of common processes and systems, these regions, including Digital Money Transfer, create one interconnected global network for consumer transactions, thereby constituting one Consumer-to-Consumer money transfer business and one operating segment.

Our revenues are primarily derived from consideration paid by customers to transfer money.

These revenues vary by transaction based upon factors such as channel, send and receive locations, the principal amount sent, whether the money transfer involves different send and receive currencies, the difference between the exchange rate set by us to the consumer and the rate available in the wholesale foreign exchange market, and speed of service, as applicable.

In a typical walk-in money transfer transaction, a consumer goes to one of our agent or subagent locations and provides information specifying, among other things, the name and other identifying information regarding the recipient, and delivers the principal amount of the money transfer and the fee to the agent or sub-agent.

Certain of these processes are streamlined for consumers who participate in our loyalty programs.

The sending agent enters the transaction information into our money transfer system and the funds are made available for pick-up by the recipient within our system, usually within minutes, in the country specified by the consumer.

In some jurisdictions, the agent collects the principal and fees after the presentation of our written disclosure that generally identifies the exchange rate and all fees and charges associated with the transaction and the consumer has agreed to the transaction, as described in the disclosure.

The agent then provides the consumer with a unique identifying number assigned by our system, which the consumer must communicate to the recipient in order to obtain the principal.

In a typical money transfer transaction, a consumer provides information, either at one of our agent or subagent locations or online, specifying, among other things, the name and other identifying information regarding the recipient and the principal amount of the transfer.

The consumer also provides funds for the transaction, including fees.

Certain of these processes are streamlined for consumers who participate in our loyalty programs or are registered westernunion.com customers.

This information is entered into our money transfer system and the funds are made available for pick-up by the recipient within our system, usually within minutes, in the country or territory specified by the consumer, or paid into the designated account of the recipient.

In some jurisdictions, the principal and fees are not collected until after the presentation of our written disclosure that generally identifies the exchange rate and all fees and charges associated with the transaction and the consumer has agreed to the transaction, as described in the disclosure.

Consumers then receive a unique identifying number assigned by our system, which the consumer must communicate to the recipient in order to obtain the principal.

The recipient generally enters an agent location in the designated receiving country or territory, presents the unique identifying number and identification, where applicable, and is paid the transferred amount by our agent based on the information in our system.

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We determine the fee paid by the sender, which generally is based on the principal amount of the transaction, the send and receive country or territory, speed of service, and channel.

We generally pay our agents a commission based on a percentage of revenue.

In a retail transaction, we generally pay our agents a commission based on a percentage of revenue.

A commission is usually paid to both the agent that initiated the transaction, the “send agent,” and the agent that paid the transaction, the “receive agent.” For most agents, the costs of providing the physical infrastructure and staff are typically covered by the agent’s primary business (e.g., postal services, banking, check cashing, travel, and retail businesses), making the economics of being a Western Union agent attractive.

Western Union’s global reach and large consumer base allow us to attract agents we believe to be well-positioned to deliver our services.

No individual country outside the United States accounted for greater than 8% of this segment’s revenue during all periods presented.

We offer money transfer services in more than 200 countries and territories, with a number of options for sending funds that provide consumers convenience and choice, through both our walk-in and online money transfer channels.

● Walk-in money transfer - The significant majority of our remittances constitute walk-in transactions in which payment is collected by one of our agents and is available for pick-up at another agent location, usually within minutes.

In a westernunion.com transaction, we typically pay a credit card processor or bank a fee for collecting the principal, and we are also responsible for losses from chargebacks and fraud, in addition to commissions owed to the receive agent.

No individual country or territory outside the United States accounted for greater than 8% of this segment’s revenue during all periods presented.

● Retail money transfer - The majority of our remittances constitute retail transactions in which payment is collected by one of our agents and is available for pick-up at another agent location, usually within minutes.

We offer a variety of methods for consumers to initiate transactions.

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Additionally, in certain agent locations, consumers can enter a transaction at a self-service kiosk and subsequently pay for the transaction at the counter of the location.

● Online money transfer - In many countries and territories, consumers can initiate a money transfer from a Western Union branded website.

Additionally, in certain countries and territories, consumers can initiate a Western Union money transfer through their bank’s online banking services.

We have also recently entered into arrangements with financial institutions and other third parties to enable such entities to offer money transfer services to their own customers under their brands.

Generally, in these arrangements, consumers agree to terms and conditions specified by the financial institution or other third party that, among other things, establish pricing paid by the consumer for the service.

Consumers can fund a transaction in a variety of ways, in addition to cash.

● Digital Money Transfer - In many countries and territories, consumers can initiate a money transfer from a Western Union branded website or mobile application or from sites and applications hosted by our third-party white label or co-branded digital partners.

Although the majority of transactions are funded with cash, consumers can fund a transaction in a variety of ways.

For example, at certain of our agent locations, consumers can fund a transaction using a debit card, and, where available, consumers can fund a money transfer from an account and through an account using an automated teller machine (“ATM”).

In our online money transfer channels, consumers can generally fund transactions using a credit card, debit card, electronic funds transfer processed through the automated clearing house (“ACH”) payment system or similar system outside the United States, online banking direct payment methods, or other bank account-based payment.

In Digital Money Transfer channels, consumers can generally fund transactions using a credit card, debit card, electronic funds transfer processed through the automated clearing house (“ACH”) payment system or similar system outside the United States, online banking direct payment methods, or other bank account-based payment.

We also provide several options for the receipt of funds.

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Many agents operate in locations that are open outside of traditional banking hours, for example on nights and weekends.

Our top 40 agents globally have been with us for more than 20 years, on average, and in 2019, these long-standing agents were involved in transactions that generated approximately 60% of our Consumer-to-Consumer revenue.

No individual agent accounted for greater than 10% of the segment’s revenue during all periods presented.

Our top 40 agents and partners globally have been with us for more than 20 years, on average, and in 2020, these long-standing relationships accounted for transactions that generated nearly 60% of our Consumer-to-Consumer revenue.

No individual agent or partner accounted for greater than 10% of the segment’s revenue during all periods presented.

We provide our third-party agents with access to our multi-currency, real-time money transfer processing systems, which are used to originate and pay money transfers.

Our systems and processes enable our agents to pay money transfers in approximately 130 currencies worldwide.

Our systems and processes enable our agents to pay money transfers in over 130 currencies worldwide.

Certain of our agents can pay in multiple currencies at a single location.

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Our international agents often customize services as appropriate for their geographic markets.

In some markets, individual agents are independently offering specific services such as stored-value card or account payout options.

In some markets, individual agents are independently offering specific services

such as stored-value card or account payout options.

While we typically perform services under the Western Union brand, in certain geographic regions, we operate under other brands targeted to the local market.

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Our marketing strategy includes a loyalty program such as “My WU SM ” which is available in certain countries and territories.

These programs offer consumers faster service at the point-of-sale and the opportunity to earn points on eligible products, such as money transfers and bill payments, and channels (including westernunion.com and mobile apps) that can be redeemed for rewards, such as reduced transaction fees.

These programs offer consumers faster service at the point-of-sale and the opportunity to earn points on eligible products, such as money transfers and bill payments, and channels (including westernunion.com and mobile applications) that can be redeemed for rewards, such as reduced transaction fees.

Redemption activity has been insignificant to the results of our operations.

We cooperate with various partners around the world to offer a variety of branded, co-branded, and unbranded money transfer services, including services offered exclusively under the partners’ brands.

While the terms of these arrangements vary, these services are often marketed by the third-party partner and offered under the partner’s license to provide money transfer services.

As a result, the regulatory requirements applicable to us under these arrangements may also vary.

Industry Trends

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Additionally, our ability to enter into or maintain exclusive arrangements with our agents has been and may continue to be challenged by both regulators and certain of our current and prospective agents.

Further, we are seeing increased competition from, and increased market acceptance of, electronic, mobile, and internet-based money transfer services as well as digital currencies.

We are seeing increased competition from, and increased market acceptance of, electronic, mobile, and internet-based money transfer services as well as digital currencies.

This trend accelerated during 2020, as consumers responded to the COVID-19 pandemic by sending money increasingly through digital channels.

We believe this shift in consumer preference will continue beyond the pandemic, resulting in an increasing proportion of remittances being sent through digital means in the future.

We face robust competition in the highly fragmented Consumer-to-Consumer money transfer industry.

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● Regional money transfer providers - Regional money transfer providers, or “niche” providers, provide the same services as global money transfer providers, but focus on a smaller group of geographic corridors or services within one region, such as North America to the Caribbean, Central or South America, or Western Europe to North Africa.

● Electronic channels - Online money transfer service providers, including certain electronic payment providers, allow consumers to send and receive money electronically using the internet or through mobile devices.

Electronic channels also include digital wallets, digital currencies, and social media and other predominantly communication or commerce-oriented platforms that offer money transfer services.

● Digital channels - Digital money transfer service providers, including certain payment providers, allow consumers to send and receive money digitally using the internet or through mobile devices.

Digital channels also include digital wallets, digital currencies, and social media and other predominantly communication or commerce-oriented platforms that offer money transfer services.

● Banks, postbanks, and post offices - Banks, postbanks, and post offices of all sizes compete with us in a number of ways, including money transfers, bank transfer and wire services, payment instrument issuances, and card-based services.

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The significant majority of our revenue in this segment is derived from foreign exchange resulting from the difference between the exchange rate set by us to the customer and the rate available in the wholesale foreign exchange market.

Customers may make an electronic transfer, wire transfer, or remit a check in order to initiate a transaction.

Our internet services are provided through our own websites and also, from time to time, in conjunction with others.

The majority of Business Solutions’ revenue was generated outside the United States during all periods presented.

Business Solutions payment transactions are conducted through various channels including the phone and via the internet.

Payments are made predominantly through electronic transfers, but in some situations, checks are remitted.

The majority of Business Solutions’ business relates to exchanges of currency at spot rates, which enable customers to make cross-currency payments.

The significant majority of Business Solutions revenue was generated outside the United States during all periods presented.

The majority of our Business Solutions business relates to exchanges of currency at spot rates, which enable customers to make cross-currency payments.

For certain industries such as educational institutions, financial institutions, and law firms, we provide tailored payment solutions.

In addition, in certain countries, we write foreign currency forward and option contracts for customers to facilitate future payments, which usually generate higher revenue per transaction than spot payments.

Payments are made predominantly through electronic transfers, wire transfers, or checks.

Distribution and Marketing Channels

Our Business Solutions services are offered primarily over the phone, through third-party channels, and via the internet.

Our Business Solutions services are offered primarily through digital channels, including through the internet and third-party channels, and over the phone.

Our internet services are marketed through our own websites as well as, from time to time, co-branding arrangements with third-party websites.

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Business-to-business payments, especially cross-border, cross-currency transactions are also dependent on global trade trends and regulations.

Increased anti-money laundering, anti-terrorist financing, consumer protection regulations and compliance requirements, and increased regulations and compliance requirements applicable to the offering of derivatives are impacting the business-to-business payments industry.

business payments industry.

We believe these increases in competition and regulatory costs are likely to continue in this segment.

Our Business Solutions segment competes with a diverse set of service providers offering payment services and foreign exchange risk management solutions, including financial institutions, other non-bank competitors, and electronic payment providers.

and clients, convenience and speed of payments network, availability of derivative products, variety of inbound and outbound payment methods, brand recognition, and price.

We believe the most significant competitive factors in this segment relate to recurring relationships founded on customer service and expertise in payments and foreign exchange, customized solutions for specific industries and clients, convenience and speed of payments network, availability of derivative products, variety of inbound and outbound payment methods, brand recognition, and price.

Our remaining businesses and services, which primarily consist of our bill payment services in Argentina and the United States and money order services, are included in Other, which also includes certain corporate costs such as costs related to strategic initiatives, including for the review and closing of mergers, acquisitions, and divestitures.

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Our bill payment services provide fast and convenient options to make payments from consumers to businesses and other organizations, including utilities, auto finance companies, mortgage servicers, financial service providers and government agencies.

Generally, these bill payment services are initiated by consumers making a cash payment at an agent or at a Company-owned location.

Generally, these bill payment services are initiated by consumers making a cash payment at an agent or at a Company-operated location.

We believe our business partners who receive payments through our services benefit from their relationship with Western Union as it provides them with real-time or near real-time posting of their customers’ payments.

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Intellectual Property

The Western Union ® logos, trademarks, service marks and trade dress are registered and/or used worldwide and are material to our Company.

The WU ® service mark and logos are also registered and used in many countries around the world.

We offer money transfer services under the Western Union, Orlandi Valuta SM and Vigo ® brands.

We also provide various payment and other services such as Western Union Business Solutions, Pago Fácil, Western Union Payments, Quick Collect, Quick Pay, Pay@WU, Quick Cash, and Convenience Pay.

The Western Union ® and WU ® trademarks and service marks, and the Company’s Black & Yellow trade dress are used and/or registered worldwide and are material to our Company.

We offer money transfer services under the Western Union ® , Orlandi Valuta ® , and Vigo ® brands.

We also provide various payment and other financial services under many brands and product names, including Western Union Business Solutions SM , Pago Fácil ® , Quick Collect ® , Quick Pay SM , Pay@WU SM , Quick Cash ® , My WU SM , and Western Union Convenience Pay ® .

Our operating results have allowed us to invest significantly each year to support our brands, and in some regions, our agents have also contributed financial resources to assist with marketing our services.

Risk Management

Our Company has a credit risk management department that evaluates and monitors our credit and fraud risks.

We are exposed to credit risk related to receivable balances from agents in the money transfer, walk-in bill payment, and money order settlement process.

We also are exposed to credit risk directly from consumer and business transactions, particularly where transactions are originated through means other than cash, such as those initiated through electronic channels, and therefore are subject to chargebacks, insufficient funds, or other collection impediments, such as fraud, which are anticipated to increase as electronic channels become a greater proportion of our business.

Our credit risk management team monitors fraud risks jointly with our information security and compliance departments, performs credit reviews before agent signings, and conducts periodic analyses of agents and certain other parties that we transact with directly.

We are exposed to additional credit risk in our Business Solutions business relating to:

(i) derivatives written by us, primarily to our customers, and (ii) the extension of trade credit when transactions are paid to recipients prior to our receiving cleared funds from the sending customers.

For the derivatives, the duration of these contracts at inception is generally less than one year.

The credit risk associated with our derivative contracts increases when foreign currency exchange rates move against our customers, possibly impacting their ability to honor their obligations to deliver currency

to us or to maintain appropriate collateral with us.

For those receivables where we have extended trade credit, collection ordinarily occurs within a few days.

To mitigate risk associated with potential customer defaults, we perform credit reviews on an ongoing basis, and, for our derivatives, we may require certain customers to post or increase collateral.

To manage our exposures to credit risk with respect to investment securities, money market fund investments, derivatives, and other credit risk exposures resulting from our relationships with banks and financial institutions, we regularly review investment concentrations, trading levels, credit spreads, and credit ratings, and we attempt to diversify our investments among global financial institutions.

A key component of the Western Union business model is our ability to manage financial risk associated with conducting transactions worldwide.

We currently settle with the substantial majority of our agents in United States dollars, euros, or Mexican pesos, requiring those agents to obtain local currency to pay recipients, and we generally do not rely on international currency markets to obtain and pay illiquid currencies.

However, in certain circumstances, we settle in other currencies.

The foreign currency exposure that does exist is limited by the fact that the majority of money transfer transactions are paid by the next day after they are initiated, and agent settlements occur within a few days in most instances.

We also utilize foreign currency forward contracts to mitigate the risks associated with currency fluctuations and to provide predictability of future cash flows.

We have additional foreign exchange risk and associated foreign exchange risk management due to the nature of our Business Solutions segment.

The majority of this business’ revenue is from exchanges of currency at spot rates, which enable customers to make cross-currency payments.

Business Solutions aggregates its foreign exchange exposures arising from customer contracts, including the derivative contracts described above, and hedges the resulting net currency risks by entering into offsetting contracts with established financial institution counterparties.

Our financial results may fluctuate due to changes in interest rates.

We review our overall exposure to floating and fixed rates by evaluating our net asset or liability position and the duration of each individual position.

We manage this mix of fixed versus floating exposure in an attempt to minimize risk, reduce costs, and improve returns.

Our exposure to interest rates can be modified by changing the mix of our interest-bearing assets as well as adjusting the mix of fixed versus floating rate debt.

The latter is accomplished primarily through the use of interest rate swaps and the decision regarding terms of any new debt issuances (i.e., fixed versus floating).

From time to time, we use interest rate swaps designated as fair value hedges to vary the percentage of fixed to floating rate debt, subject to market conditions.

Additionally, we own patents and patent applications covering various aspects of our products and services, covering a broad range of technologies, including those related to money transfer, compliance analytics, fraud prevention, and mobile applications.

We also own a number of application programming interfaces.

Our business is subject to a wide range of laws and regulations enacted by the United States federal government, each of the states, many localities, and many other countries and jurisdictions, including the EU.

These include increasingly strict legal and regulatory requirements intended to help detect and prevent money laundering, terrorist financing, fraud, and other illicit activity.

These include increasingly

strict legal and regulatory requirements intended to help detect and prevent money laundering, terrorist financing, fraud, and other illicit activity.

These also include laws and regulations regarding financial services, consumer disclosure and consumer protection, currency controls, money transfer and payment instrument licensing, payment services, credit and debit cards, electronic payments, foreign exchange hedging services and the sale of spot, forward and option currency contracts, unclaimed property, the regulation of competition, consumer privacy, data protection, and information security.

Failure by Western Union, our agents, or their subagents (agents and subagents are third parties, over whom Western Union has limited legal and practical control), and certain of our service providers to comply with any of these requirements or their interpretation could result in regulatory action, the imposition of civil and criminal penalties, including fines and restrictions on our ability to offer services, the suspension or revocation of a license or registration required to provide money transfer services and/or payment services or foreign exchange products, the limitation, suspension or termination of services, changes to our business model, loss of consumer confidence, private class action litigation, and/or the seizure of our assets.

For example, in early 2017, we entered into the Joint Settlement Agreements, and in early 2018, we agreed to a consent order which resolved a matter with the New York State Department of Financial Services (the “NYDFS Consent Order”), as further discussed in Part II, Item 8, Financial Statements and Supplementary Data , Note 6, Commitments and Contingencies.

For example, in early 2017, we entered into a Deferred Prosecution Agreement with the United States Department of Justice and certain United States Attorney’s Offices (the “DPA”), a Stipulated Order for Permanent Injunction and Final Judgment (the “FTC Consent Order”) with the United States Federal Trade Commission (“FTC”), a Consent to the Assessment of Civil Money Penalty with the Financial Crimes Enforcement Network (“FinCEN”) of the United States Department of Treasury (the “FinCEN Agreement”), and settlement agreements with various state attorneys general (collectively, the “Joint Settlement Agreements”) and in early 2018, we agreed to a consent order which resolved a matter with the New York State Department of Financial Services (the “NYDFS Consent Order”).

For further discussion of these agreements, please see Part I, Item 1A, Risk Factors - “Our business is the subject of consent agreements with or enforcement actions by regulators.”

We have developed and continue to enhance our global compliance programs, including our anti-money laundering program, comprised of policies, procedures, systems, and internal controls to monitor and to address various legal and regulatory requirements.

In addition, we continue to adapt our business practices and strategies to help us comply with

current and evolving legal standards and industry practices, including heightened regulatory focus on compliance with anti-money laundering or fraud prevention requirements.

In addition, we continue to adapt our business practices and strategies to help us comply with current and evolving legal standards and industry practices, including heightened regulatory focus on compliance with anti-money laundering or fraud prevention requirements.

As of December 31, 2020, these programs included dedicated compliance personnel, training and monitoring programs, suspicious activity reporting, regulatory outreach and education, and support and guidance to our agent network on regulatory compliance.

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Compliance with anti-money laundering laws and regulations continues to be a focus of regulatory attention, with recent settlement agreements being reached with Western Union, other money transfer providers, and several large financial institutions.

For example, in early 2017, we entered into the Joint Settlement Agreements, and in early 2018, we agreed to the NYDFS Consent Order, as further discussed in Part II, Item 8, Financial Statements and Supplementary Data , Note 6, Commitments and Contingencies.

For example, in early 2017, we entered into the Joint Settlement Agreements, and in early 2018, we agreed to the NYDFS Consent Order.

Economic and trade sanctions programs administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and by certain foreign jurisdictions prohibit or restrict transactions to or from (or dealings with or involving) certain countries, regions, governments, and in certain circumstances, specified foreign nationals, as well as with certain individuals and entities such as narcotics traffickers, terrorists, and terrorist organizations.

We provide limited money transfer and payment services to parties in Cuba, Syria, and the Crimea region of Ukraine in accordance with United States laws authorizing such services, and pursuant to and as authorized by advisory opinions of, or specific or general licenses issued by, OFAC.

In October 2019, OFAC implemented new limits on remittances and other funds transfers involving Cuba.

These limits are likely to increasingly restrict our ability to provide money transfer and payment services with respect to Cuba.

We provide limited money transfer and payment services to parties in Syria and the Crimea region of Ukraine in accordance with United States laws authorizing such services, and pursuant to and as authorized by advisory opinions of,

or specific or general licenses issued by, OFAC.

In October 2020, OFAC amended its Cuban Assets Control Regulations, requiring us to suspend our money transfer services to Cuba.

In the United States, almost all states license certain of our services and many exercise authority over the operations of certain aspects of our business and, as part of this authority, regularly examine us.

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The substantial majority of our investment securities, classified within Settlement assets in the Consolidated Balance Sheets, are held in order to comply with state licensing requirements in the United States and are required to have credit ratings of “A-” or better from a major credit rating agency.

These licensing laws also cover matters such as government approval of controlling shareholders and senior management of our licensed entities, regulatory approval of agents and in some instances their locations, consumer disclosures and the filing of periodic reports by the licensee, and require the licensee to demonstrate and maintain certain net worth levels.

These licensing laws also cover matters such as government approval of controlling shareholders and senior management of our licensed entities, regulatory approval of agents and in some instances their locations, consumer disclosures and the filing of periodic reports by the licensee, and they may require the licensee to demonstrate and maintain certain net worth levels.

Many states also require money transfer providers and their agents to comply with federal and/or state anti-money laundering laws and regulations.

Outside the United States, our money transfer business is subject to some form of regulation in almost all of the countries and territories in which we offer those services.

These laws and regulations may include limitations on what types of entities may offer money transfer services, agent registration requirements, limitations on the amount of principal that can be sent into or out of a country, limitations on the number of money transfers that may be sent or received by a

consumer, and controls on the rates of exchange between currencies.

They also include laws and regulations intended to detect and prevent money laundering or terrorist financing, including obligations to collect and maintain information about consumers, recordkeeping, reporting and due diligence, and supervision of agents and subagents similar to and in some cases exceeding those required under the BSA.

In most countries, either we or our agents are required to obtain licenses or to register with a government authority in order to offer money transfer services, and in certain countries, we must maintain sufficient cash or other funds to satisfy payout obligations in these countries.

The majority of our EU business is managed through our Irish payment institution subsidiary, which is regulated by the Central Bank of Ireland under the Second EU Payment Services Directive EU 2015/2366 (“PSD2”).

Where we cooperate with partners around the world to offer other branded and unbranded money transfer services, including services offered and marketed exclusively under the partners’ brands, the regulatory requirements applicable to us may vary.

PSD2 imposes rules on payment service providers like Western Union.

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Its aim is to drive increased competition, innovation, and transparency across the EU payments market, while enhancing consumer protection and the security of internet payments and account access.

To achieve this, PSD2 (i) has increased the supervisory powers granted to member states with respect to activities performed by companies such as Western Union, and our agent network, (ii) provides for customer identity verification and authentication measures, and agent monitoring responsibilities, (iii) provides member states with the ability to limit the types, nature, and amount of charges we may assess, increases customer refund rights, and (iv) increases information security and incident reporting responsibilities.

Under PSD2, we are responsible for the regulatory compliance of our agents and their subagents.

We are also subject to requirements such as investment safeguarding rules and periodic examinations similar to those in the United States.

To achieve this, PSD2:

(i) has increased the supervisory powers granted to member states with respect to activities performed by companies such as Western Union, and our agent network, (ii) provides for customer identity verification and authentication measures, and agent monitoring responsibilities, (iii) provides member states with the ability to limit the types, nature, and amount of charges we may assess, increases customer refund rights, and (iv) increases information security and incident reporting responsibilities.

Under our PSD2 license and local EU member states’ implementing legislation and associated regulatory supervisory powers, we are responsible for the regulatory compliance of our agents and their subagents.

We are also subject to requirements such as capital and safeguarding rules, certain consumer protection requirements, information technology, and operational security risk management requirements, outsourcing oversight requirements, and periodic regulatory examinations similar to those in the United States.

These rules have resulted in increased compliance and agent monitoring costs and the increased risk of adverse regulatory action against us resulting from the actions of our agents in those areas.

In addition to increasing our compliance costs, PSD2 increases the regulatory supervision and enforcement associated with non-compliance with it and the associated European Banking Authority guidelines and regulatory technical standards.

In addition to increasing our compliance costs, PSD2 increases the regulatory supervision and enforcement associated with non-compliance with it and the associated increasing body of applicable European Banking Authority guidelines and regulatory technical standards.

PSD2 may also result in increased competition arising from other service providers utilizing the enhanced payment initiation and account information access provisions or by our failure to utilize those provisions to innovate our own service offerings.

We continue to monitor PSD2’s impact, including indicators of potential increases in competition such as the number of new payment and electronic money license authorizations, including those by multinational online service and technology companies, and the number of newly-licensed payment initiation and account information service providers.

We continue to monitor PSD2’s impact, including indicators of potential increases in competition such as the number of new payment and electronic money license authorizations, including those by

multinational online service and technology companies, and the number of newly-licensed payment initiation and account information service providers.

In addition to our Irish PSD2 license, which covers most of our retail money transfer business in Europe, our European digital money transfer business is managed through our Austrian banking subsidiary, which is regulated by the Austrian Financial Market Authority under the Austrian Banking Act.

Its digital money transfer business is subject to payment services regulated under PSD2 and local implementing legislation.

The United Kingdom (“UK”) left the EU on January 31, 2020 (“Brexit”), following a referendum and a notification to the EU, under Article 50 of the Treaty on the European Union.

In advance of Brexit, the UK and the EU ratified an agreement governing the terms of the UK’s withdrawal from the EU (the “Withdrawal Agreement”).

Under the terms of the Withdrawal Agreement, certain regulated financial service providers were permitted to continue to rely on EU regulatory “passport” rights until December 31, 2020 to provide services between the UK and EU without needing to obtain separate local regulatory authorizations in the relevant jurisdictions.

To ensure that our operations will continue in the UK, which represented approximately 6% of our consolidated revenues for the year ended December 31, 2020, we set up a new payment institution to conduct money remittance in the UK, which was authorized by the Financial Conduct Authority in April 2019, and presently offers retail money transfer services via UK agents.

We have also applied for the UK branch of our Austrian banking subsidiary to be authorized by the UK Prudential Regulation Authority (the “PRA”) as a Third Country Branch (i.e., a UK branch of a non-UK bank) in order to continue to conduct our UK Business Solutions and digital money transfer operations.

The PRA has a period of 3 years from December 31, 2020 to determine the application.

In the period from December 31, 2020 and the date of the UK branch being authorized, it will operate under the Temporary Permissions Regime established by the UK for this purpose.

This UK branch will be subject to certain additional UK regulatory requirements upon authorization.

Further, as a result of Brexit, including under the terms of any new regulatory authorizations we have and may obtain, we could be required to comply with differing regulatory requirements in the UK as a result of divergence from established EU regulation.

This could make it more costly for us to provide our services.

Regulators worldwide are exercising heightened supervision of money transfer providers and requiring increasing efforts to ensure compliance, including as a result of PSD2 and the 4 th and 5 th Anti-Money Laundering Directives in the EU.

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● limit the number or principal amount of money transfers, which may be sent to or from a jurisdiction, whether by an individual, through one agent, or in aggregate;

● restrict or limit our ability to process transactions using centralized databases, including cloud computing infrastructure and software, for example, by requiring that transactions be processed using a database maintained in a particular country or region;

● impose more stringent information technology, cybersecurity, data, and operational security requirements on us or our agents and their subagents, including relating to data transfers and the use of cloud infrastructure;

● impose additional risk management and related governance and oversight requirements, including relating to the outsourcing of services to other group companies or to third parties;

● prohibit or limit exclusive arrangements with our agents and subagents.

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Derivatives Regulations

Rules adopted under the Dodd-Frank Act by the Commodity Futures Trading Commission (the “CFTC”), as well as the provisions of the European Market Infrastructure Regulation and its technical standards, which are directly applicable in the member states of the EU, have subjected most of our foreign exchange hedging transactions, including certain

intercompany hedging transactions, certain of the corporate interest rate hedging transactions we may enter into in the future, and certain of the foreign exchange derivatives contracts we offer as part of our Business Solutions segment, to reporting, recordkeeping, and other requirements.

Additionally, certain of the corporate interest rate hedging transactions and foreign exchange derivatives transactions we may enter into in the future may be subject to centralized clearing requirements or may be subject to margin requirements in the United States and EU.

Other jurisdictions outside of the United States and the EU are considering, have implemented, or are implementing regulations similar to those described above.

Rules adopted under the Dodd-Frank Act by the Commodity Futures Trading Commission (the “CFTC”), as well as the provisions of the European Market Infrastructure Regulation and its technical standards, which are directly applicable in the member states of the EU and in the UK, have subjected most of our foreign exchange hedging transactions, including certain intercompany hedging transactions, certain of the corporate interest rate hedging transactions we may enter into in

the future, and certain of the foreign exchange derivatives contracts we offer as part of our Business Solutions segment, to reporting, recordkeeping, and other requirements.

Other jurisdictions outside of the United States, the EU, and the UK are considering, have implemented, or are implementing regulations similar to those described above.

Derivatives regulations have added costs to our business and any additional requirements, such as future registration requirements and increased regulation of derivatives contracts, will result in additional costs or impact the way we conduct our hedging activities as well as impact how we conduct our business within our Business Solutions segment.

In 2016, the CFTC published a proposed rule that, if adopted as proposed, would have increased the likelihood that we would have had to register one or more of our subsidiaries with the CFTC as a swap dealer.

In early 2020, the CFTC withdrew the 2016 proposal and replaced it with a new proposed rule that, if adopted as proposed, we believe will decrease that likelihood relative to the 2016 proposal.

However, there does remain some risk that we will have to register one or more of our subsidiaries with the CFTC as a swap dealer in the future.

Swap dealers are subject to a comprehensive regulatory framework and compliance with this framework will lead to additional costs, including costs relating to regulatory capital and margin requirements, and may impact how we conduct our hedging activities and derivatives business with customers.

We continue to consider the impact the proposed rule, if adopted, would have on our hedging activities and operations.

Although currently unlikely due to our derivative activity levels, there is some risk that we will have to register one or more of our subsidiaries with the CFTC as a swap dealer in the future.

Swap dealers are subject to a comprehensive regulatory framework and compliance with this framework would lead to additional costs, including costs relating to regulatory capital and margin requirements, and could impact how we conduct our hedging activities and derivatives business with customers.

For further discussion of these risks, see Part I, Item 1A, Risk Factors - “The Dodd-Frank Act, as well as the regulations required by that Act and the actions of the Consumer Financial Protection Bureau and similar legislation and regulations enacted by other government authorities, could adversely affect us and the scope of our activities, and could adversely affect our financial condition, results of operations, and cash flows.” Our implementation of these requirements has resulted, and will continue to result, in additional costs to our business.

Additionally, the regulatory regimes for derivatives in the United States and EU, such as under the Dodd-Frank Act and the European Markets in Financial Instruments Directive known as “MiFID II,” are continuing to evolve.

Additionally, the regulatory regimes for derivatives in the United States, the EU, and the UK, such as under the Dodd-Frank Act and the European Markets in Financial Instruments Directive known as “MiFID II,” are continuing to evolve.

Any changes to such regimes, or our designation or the implementation of new rules under these regimes, such as future registration requirements and increased regulation of derivatives contracts, may result in additional costs to our business.

Other jurisdictions outside the United States and the EU are considering, have implemented, or are implementing regulations similar to those described above and these will result in greater costs to us as well.

Other jurisdictions outside the United States, the EU, and the UK are considering, have implemented, or are implementing regulations similar to those described above and these will result in greater costs to us as well.

Moreover, as a result of Brexit, we could be required to comply with differing regulatory requirements in the UK as a result of divergence from established EU regulation.

This could make it more costly for us to provide our services.

Furthermore, our failure to implement these requirements correctly could result in fines and other sanctions, as well as necessitate a temporary or permanent cessation to some or all of our derivative related activities.

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These laws and requirements continue to evolve and may become increasingly difficult to comply with.

In the United States, federal data privacy laws such as the federal Gramm-Leach-Bliley Act and various state laws, such as data privacy and breach laws, apply to a broad range of financial institutions including money transfer providers

like Western Union, and to companies that provide services to or on behalf of those institutions.

The United States Federal Trade Commission (“FTC”), which has jurisdiction over companies such as Western Union, has brought numerous enforcement actions, resulting in multi-year settlements, against companies whose privacy or data security practices allegedly violated the law.

allegedly violated the law.

We are also subject to privacy and data breach laws in various states, such as the California Consumer Privacy Act, which became effective on January 1, 2020, that imposes heightened data privacy requirements on companies that collect information from California residents and creates a broad set of privacy rights and remedies modeled in part on the GDPR, as discussed below.

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Such notification requirements may be subject to various factors, including the level of encryption, the data elements involved in the incident, and the potential harm to consumers.

In addition, the Company is also subject to United States federal reporting requirements in connection with some such incidents.

In addition, we are also subject to United States federal reporting requirements in connection with some such incidents.

Increasingly, data protection laws of countries outside of the United States are having a significant impact on our operations and the manner in which we provide our services.

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These laws present operational and technology challenges that can require companies to make significant changes to the management of personal information and can potentially increase our costs and impact our ability to process personal information.

These laws may also restrict or limit our ability to process transactions using centralized databases, including cloud computing infrastructure and software, for example, by requiring that transactions be processed using a database maintained in a particular country or region.

Data privacy regulations, laws, and industry standards also impose requirements for safeguarding personal information.

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We are subject to annual reviews to ensure compliance with PCI regulations worldwide and are subject to fines if we are found to be non-compliant.

Employees and Labor

As of December 31, 2019, our businesses employed approximately 11,500 employees, of which approximately 1,900 employees are located inside the United States.

Human Capital Management

As of December 31, 2020, our businesses employed approximately 11,000 individuals, of which approximately 1,700 employees are located inside the United States.

Our employees span more than 50 countries.

Attracting, Developing, and Engaging Employees

Our recruitment efforts focus on identifying internal and external talent with skills that are critical to our business strategy, including those individuals with cloud, data architecture, cybersecurity, payment systems, and many other areas of expertise.

We actively assess our new talent needs, evaluate the extent to which current staff have those critical skills, and provide development to build these capabilities.

Our recruiting team uses multiple channels to find, assess, and hire employees, including channels that focus on diverse candidates.

Training and Professional Development

We invest in our people and their growth.

Our talent processes endeavor to strike an appropriate balance between global scale and local responsiveness.

Our development and training organization has members in many countries, so that training can be made available to all regions of our global workforce.

Our employee development philosophy centers around learning and empowerment.

To position our people for success, we provide our employees with access to a variety of learning, including self-paced digital and facilitated formats.

Employees also gain valuable experiences through on the job learning, special assignments and projects, and coaching and mentoring.

We use a variety of assessments to help employees identify and develop areas to both improve current performance as well as areas that prepare them for future opportunities.

Reflecting our commitment to a culture of ethics and compliance, new employees receive mandatory education related to compliance, ethics, privacy, and information security.

Existing employees receive continuing education on these same topics every year.

We assess employee engagement regularly, and our employee engagement system utilizes monthly surveys, artificial intelligence, and machine learning to help leaders better understand what our employees are thinking, what they value, and what they need.

We benchmark our engagement results against global peers to better understand our strengths and areas of opportunity.

One of our ongoing goals is to foster greater communication to help ensure that our employees are informed, believe that their concerns are heard, and feel empowered to make decisions.

To that end, we have implemented employee engagement and culture teams in certain of our offices worldwide.

While each site varies somewhat in its approach, these “Empower” teams are supported by on-site business leaders to focus on the “culture of the customer,” diversity and inclusion, community, the environment, and other issues that are meaningful to employees in those locations.

Diversity, Equity, and Inclusion

We are committed to fostering a diverse and inclusive work environment.

We recognize the strategic importance of talent and diversity in our workforce and promote diversity through:

● our policies and practices in hiring, promotion, and compensation;

● encouraging ethical decision-making via our Code of Conduct and ethics training program;

● offering diversity training programs, sponsorship, and mentoring initiatives;

● unconscious bias training;

● goal setting;

● providing support for grassroots affinity groups and belonging initiatives.

For example, as of December 31, 2020, over 50% of our global workforce were women, over 35% of senior management-level and above positions were held by women, and one-third of our executive officers were women.

Our leadership team has diverse backgrounds, with wide-ranging, global experience.

In addition, our Board of Directors considers diversity in gender, ethnicity, geography, background, and cultural viewpoints when selecting nominees.

As of December 31, 2020, five of our eleven directors were diverse, including three directors who were female and three directors who identify as Latinx, Asian, or LGBTQ+.

Compensation, Benefits, and Wellness

We seek to provide compensation that motivates, retains, and rewards our employees and attracts future talent.

We offer packages designed to inspire the delivery of exceptional performance and results to help us deliver on our business strategy, stockholder commitments, and Company values.

To guide our annual compensation assessment, we examine and benchmark market data for countries where we operate, as available data allows.

We strive to achieve equal pay for equal work.

We consistently review and update salary ranges and perform internal pay equity reviews, with the goal of developing impartial and competitive pay practices and aligning salaries to local

market conditions and cost-of-labor changes.

We also offer employees multiple channels to raise pay equity concerns, such as our human resources team, ethics helpline, and legal department.

Our benefit packages aim to support the health and well-being of our employees and their families, including same and opposite sex domestic partners in most countries.

Our benefit packages vary among countries based on laws, cultural norms, and market practices.

Benefits generally available to all full-time employees include medical benefits, risk insurance benefits (life, disability, and accidental death and dismemberment), global adoption assistance, our employee assistance program (counseling, legal, and other professional services), paid leave, a scholarship program available to employees with college-age children, a global recognition and reward program, and business travel assistance and insurance.

During the COVID-19 pandemic, we have introduced multiple new benefits, working arrangements, and trainings to support the mental and physical health and financial security of our employees.

These included the ability to work from home for the majority of employees, along with work-from-home tools, resources, and support, and in certain cases, enhanced back-up and in-home child and elder care, additional paid sick and family leave for employees affected by COVID-19, and telehealth doctor visits and enhanced health insurance services.

In addition, we have introduced an internet subsidy and a one-time equipment support bonus for a portion of the employee population below the senior management level.

To continue support for employees in 2021, we have expanded the back-up child and elder care benefit to multiple countries, implemented a global tutoring benefit for employees and their children to support remote learning, and supported our employees’ mental and emotional health through the implementation of an award-winning meditation and sleep application.

Available Information

11 unchanged sentences

Jacqueline Molnar

Chief Transformation Officer and Global Head of Compliance

Chief Transformation Officer

Michelle Swanback

1 unchanged sentence

Andrew Summerill

Interim President, Payments

President, Payments

Caroline Tsai

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Chief People Officer

Hikmet Ersek is our President and Chief Executive Officer (from September 2010) and a member of the Company’s Board of Directors (from April 2010).

From January 2010 to August 2010, Mr.

Hikmet Ersek is our President and Chief Executive Officer and a member of the Company’s Board of Directors (from 2010).

Also during 2010, Mr.

Ersek served as the Company’s Chief Operating Officer.

Prior to January 2010, Mr.

Ersek served as the Company’s Executive Vice President and Managing Director, Europe, Middle East, Africa and Asia Pacific Region from December 2008.

From September 2006 to December 2008, Mr.

Prior to 2010, Mr.

Ersek served as the Company’s Executive Vice President and Managing Director, Europe, Middle East, Africa and Asia Pacific Region from 2008.

From 2006 to 2008, Mr.

Ersek served as the Company’s Executive Vice President and Managing Director, Europe/Middle East/Africa/South Asia.

Prior to September 2006, Mr.

Prior to 2006, Mr.

Ersek held various positions of increasing responsibility with Western Union.

Prior to joining Western Union in September 1999, Mr.

Prior to joining Western Union in 1999, Mr.

Ersek was with GE Capital specializing in European payment systems and consumer finance.

Raj Agrawal is our Chief Financial Officer (from July 2014), and previously served as Executive Vice President of Global Operations (from December 2017 to June 2019), and Executive Vice President and Interim Chief Financial Officer from January 2014 to July 2014.

Prior to January 2014, Mr.

Agrawal served as President, Western Union Business Solutions from August 2011.

Prior to August 2011, Mr.

Agrawal served as General Manager, Business Solutions from November 2010, and as Senior Vice President of Finance for Business Units from August 2010 to November 2010.

Raj Agrawal is our Chief Financial Officer (from 2014), and previously served as Executive Vice President of Global Operations (from 2017 to 2019), and Executive Vice President and Interim Chief Financial Officer during 2014.

From 2011 to 2014, Mr.

Agrawal served as President, Western Union Business Solutions.

From 2010 to 2011, Mr.

Agrawal served as General Manager, Business Solutions, and as Senior Vice President of Finance for Business Units.

Previously, Mr.

Agrawal served as Senior Vice President of Finance of the Company’s Europe, Middle East, and Africa and Asia Pacific regions from July 2008 to August 2010, and as Senior Vice President and Treasurer of Western Union from June 2006 to May 2008.

Agrawal served as Senior Vice President of Finance of the Company’s Europe, Middle East, and Africa and Asia Pacific regions from 2008 to 2010, and as Senior Vice President and Treasurer of Western Union from 2006 to 2008.

Prior to joining Western Union in 2006, Mr.

Agrawal served as Treasurer and Vice President of Investor Relations at Deluxe Corporation, and worked at General Mills, Inc., Chrysler Corporation, and General Motors Corporation.

Jean Claude Farah is our President, Global Network (from July 2019).

From February 2017 to July 2019, Mr.

Farah served as Executive Vice President and President, Global Payments, from December 2013 to February 2017, Mr.

Farah served as Executive Vice President and President, Middle East, Africa, APAC, Eastern Europe and CIS, and from March 2009 to December 2013, Mr.

Farah served as Senior Vice President for the Middle East and Africa region at Western Union.

Jean Claude Farah is our President, Global Network (from 2019).

From 2017 to 2019, Mr.

Farah served as Executive Vice President and President, Global Payments, from 2013 to 2017, Mr.

Farah served as Executive Vice President and President, Middle East, Africa, APAC, Eastern Europe and CIS, and from 2009 to 2013, Mr.

Farah served as Senior Vice President for the Middle East and Africa region.

Farah joined Western Union in 1999 as Marketing Manager, Middle East & North Africa.

He has held a variety of progressively responsible positions with the company, including Regional Director from March 2003 to June 2005, Regional Vice President from June 2005 to March 2009 and Senior Vice President for the Middle East, Pakistan and Afghanistan region.

He has held a variety of progressively responsible positions with the company, including Regional Director, Regional Vice President and Senior Vice President for the Middle East, Pakistan and Afghanistan region.

Farah started his career in 1995 with Renault SA.

Prior to joining Western Union, he was Area Manager for Orangina Pernod Ricard.

Khalid Fellahi is our President, Consumer Money Transfer (from July 2019).

From January 2011 to July 2019, Mr.

Fellahi served as Senior Vice President and General Manager for Western Union Digital, and Head of our Africa region and the Mobile Transaction Services group from 2005 to 2011.

Prior to joining Western Union in October 2002, Mr.

Khalid Fellahi is our President, Consumer Money Transfer (from 2019).

From 2011 to 2019, Mr.

Fellahi served as Senior Vice President and General Manager for Western Union Digital, and Head of our Mobile Transaction Services group from 2009 to 2010.

Prior to that, Mr.

Fellahi served as Head of our Africa region from 2002 to 2009.

Prior to joining Western Union in 2002, Mr.

Fellahi held roles within SIS-Groupe Compagnie Bancaire (Paribas) and Price Waterhouse Management Consultants.

In addition, he has held senior leadership positions at small and medium enterprises in the service industry.

Jacqueline Molnar is our Chief Transformation Officer and Global Head of Compliance (from July 2019).

Molnar served as Chief Compliance Officer from March 2016 to July 2019 and Senior Vice President and Deputy Chief Compliance Officer from September 2013 to February 2016.

Jacqueline Molnar is our Chief Transformation Officer (from 2020).

Molnar served as Chief Transformation Officer and Global Head of Compliance from 2019 to 2020, Chief Compliance Officer from 2016 to 2019, Interim Chief Compliance Officer from 2015 to 2016, and Senior Vice President and Deputy Chief Compliance Officer from 2013 to 2015.

Prior to joining Western Union in 2013, Ms.

Molnar served

as Vice President, Associate Global Anti-Money Laundering Officer at Toronto Dominion Bank Group, as Vice President, Assistant General Counsel at Wells Fargo & Company, and in various roles at Gibson Dunn, Latham & Watkins LLP, and at Herbert Smith Freehills.

Michelle Swanback is our President, Product and Platform (from January 2020).

From January 2014 to January 2020, Ms.

Swanback served as the Group Operating Officer at Accenture Digital where she was responsible for accelerating growth, executing business strategy, and leading the global business operations.

She previously served as the lead for Accenture Technology, North America from August 2012 to January 2014, where she was accountable for sales support, solution design, and delivery of Accenture’s technology services and offerings.

Prior to that, she served as a managing director in the North American operating unit of the Accenture Communications, Media, and Technology operating group from February 2011 to August 2012.

Andrew Summerill is our Interim President, Payments (from July 2019).

From April 2015 to June 2019, Mr.

Summerill served as Chief Financial Officer of Western Union Business Solutions and as Vice-President of Finance for Asia Pacific of Western Union Business Solutions from May 2010 to March 2015.

Molnar served as Vice President, Associate Global Anti-Money Laundering Officer at Toronto Dominion Bank Group, as Vice President, Assistant General Counsel at Wells Fargo & Company, and in various roles at Gibson Dunn, Latham & Watkins LLP, and at Herbert Smith Freehills.

Michelle Swanback is our President, Product and Platform (from 2020).

From 2014 to 2020, Ms.

Swanback served as the Group Operating Officer at Accenture Digital.

She previously served as the lead for Accenture Technology, North America from 2012 to 2014.

Prior to that, she served as a managing director in the North American operating unit of the Accenture Communications, Media, and Technology operating group from 2011 to 2012.

Andrew Summerill is our President, Payments (from 2020).

From 2019 to 2020, Mr.

Summerill served as our Interim President, Payments.

From 2015 to 2019, Mr.

Summerill served as Chief Financial Officer of Western Union Business Solutions and as Vice-President of Finance for Asia Pacific of Western Union Business Solutions from 2010 to 2015.

Summerill joined Western Union with the 2011 acquisition of Travelex Global Business Payments, where he held various positions.

Caroline Tsai is our Chief Legal Officer and Corporate Secretary (from July 2019).

From December 2017 to July 2019, Ms.

Caroline Tsai is our Chief Legal Officer and Corporate Secretary (from 2019).

From 2017 to 2019, Ms.

Tsai served as Executive Vice President, General Counsel and Secretary.

Prior to joining Western Union in December 2017, Ms.

Tsai served as Deputy General Counsel and Chief Regulatory Officer of BMO Financial Group, a banking and financial services provider, from December 2015 to November 2017 and from January 2014 to December 2015, Ms.

Prior to joining Western Union in 2017, Ms.

Tsai served as Deputy General Counsel and Chief Regulatory Officer of BMO Financial Group, a banking and financial services provider, from 2015 to 2017 and from 2014 to 2015, Ms.

Tsai served as Chief Legal Officer, U.S.

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Prior to joining BMO Financial Group, Ms.

Tsai was Senior Vice President and Associate General Counsel of Bank of America Corporation, a banking and financial services provider, from January 2012 to December 2013, and from July 2005 to December 2011, Ms.

Tsai was Senior Vice President and Associate General Counsel of Bank of America Corporation, a banking and financial services provider, from 2012 to 2013, and from 2005 to 2011, Ms.

Tsai served as Senior Vice President and Assistant General Counsel.

Tsai began her legal career as an Associate with the law firm Jones Day, based in Washington, D.C.

Richard Williams is our Chief People Officer (from July 2019).

Williams previously served as Executive Vice President, Chief Human Resources Officer from October 2013 to July 2019, Interim Chief Human Resources Officer from March 2013 to October 2013 and as Senior Vice President, Human Resources - Global Consumer Financial Services from June 2011 to October 2013.

Williams joined Western Union in November 2009 as the Vice President of Human Resources for the Americas and Global Cards.

Richard Williams is our Chief People Officer (from 2019).

Williams previously served as Executive Vice President, Chief Human Resources Officer from 2013 to 2019, Interim Chief Human Resources Officer during 2013 and as Senior Vice President, Human Resources - Global Consumer Financial Services from 2011 to 2013.

Williams joined Western Union in 2009 as the Vice President of Human Resources for the Americas and Global Cards.

Before joining Western Union, Mr.

Williams worked for Fullerton Financial Holdings (a wholly-owned subsidiary of Temasek Holdings) as its Senior Vice President of Human Resources for Central and Eastern Europe, Middle East and Africa, based in Dubai, United Arab Emirates from September 2007 to October 2009.

Previously, Mr.

Williams spent 17 years (May 1998 to August 2007 and August 1989 to February 1997) with American Express Company.

Williams spent 17 years with American Express Company.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business