1. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. Document Number FAC001 The Government Sanctions List

2. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 2 Government Sanctions and Interdiction Program Who Implements Financial Sanctions?  Many countries throughout the world implement trade and financial sanctions in one form or another, either directly or indirectly. Government entities that directly issue financial sanctions lists include: Argentina, Australia, Canada, the European Union, Hong Kong, Russia, the United Kingdom and the United States, among others. Why Are Financial Sanctions Implemented?  Various governments around the world require financial institutions to review their transactions against lists of people subject to financial sanctions.  The governments that maintain these lists have determined that the people or entities on these lists are linked with, support, or benefit from some sort of unlawful activity, such as drug trafficking, terrorism or terrorist financing, humanitarian or financial crime or fraud. How Western Union complies with Financial Sanctions.  Western Union complies with these requirements by reviewing its transactions against these lists on a worldwide basis.  Western Union also maintains a list of people with whom the company will not conduct business.

3. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 3 Government Sanctions and Interdiction Program Western Union actively cooperates with all legitimate governmental inquiries and investigations. When our software identifies transactions that appears to have been sent by or designated for someone who appears on one of the lists, the transaction is suspended and analysed by compliance and treated in accordance with law. If the transaction is delayed or suspended, please contact the regional Compliance Officer or IROC. Transactions resulting in a positive match against these lists are blocked and retained in a separate account pending notification of the appropriate government agency. Under no circumstances can the transaction be refunded back to the sender, or have the name changed, until the potential matched is resolved!

4. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 4 Dealing with consumer complaints The consumer believes he has been interdicted in error The consumer has a similar name with someone on the interdiction list Please, provide the following details to: wuamlcompliance@westernunion.com 1.Money Transfer Control Number (MTCN) 2.Full consumer name (first, middle, last) 3.ID 4.Date of Birth 5.Purpose of the transaction 6.Relationship of the sender and receiver Under no circumstances should the transaction be changed or reinstated after being determined to be valid interdiction!

5. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 5 How to answer consumer’s questions? International laws require Western Union to review transactions against a list of people who are subject to government financial sanctions. Unfortunately, your name / receiver’s name is similar to a name on the list and your transaction has been suspended until you can provide some additional information. We want to help you. In order to clear your transaction, we need to provide Western Union with:  a passport or a current, government-issued photo ID with your full and complete name; date of birth; country of birth; the ID type and number; country of issuance and expiration date.  your address and telephone number  the Money Transfer Control Number and transaction date. We apologize for this inconvenience, but once you provide this information, it is likely that your transaction will be cleared quickly.

6. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 6 How to answer consumer’s questions? Q: “Forget the transaction – give me my money back.” Q: “I don’t want to / have to provide any additional information.” A: Western Union cannot legally refund your money or pay the transaction until they get additional information. Once a transaction enters the Western Union system and it is identified as a potential match, international laws prohibit Western Union from releasing the transaction until they can verify that it is not a match.

7. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 7 How to answer consumer’s questions? Q: “I’m not sending money to the United States or to a country that has sanctions. Why does this apply to me?” A: Western Union is required by international law to review transactions regardless of their origin or destination. It is a requirement of international law, not just U.S. law.

8. Western Union Confidential ©2009 Western Union Holdings, Inc. All Rights Reserved. 8 How to answer consumer’s questions? Q: “Does Western Union think I am a criminal?” Q: “Western Union is discriminating against me.” A: No, not at all. Western Union is required by international law to review transactions against a list of people that are subject to government financial sanctions. Western Union also has a list of people with which it will not do business. Western Union is required by law to research all possible name matches. Western Union does not discriminate against any race, religion, colour, creed or gender.