Team size : nine

Key team members:

We are a cross-functional team of regional lawyers, paralegals and company secretaries representing our global business legal, corporate governance, product legal, regulatory legal and privacy teams.

Privacy: Gráinne Murphy, managing associate general counsel, global head of privacy legal; Lee Taren, privacy counsel; Natalia Mamaladze, leader, privacy operations

Regulatory: Feidhlimidh Wrafter, assistant general counsel, EU Regulatory & DPO

Corporate Governance: Laura Dunne, managing counsel, corporate governance; Eamon Stewart, company secretary, Kate Scanlon, company secretary; Edobor Osagie, privacy operations

Product: Ellen Chesser, product counsel

What are the most significant cases or transactions that your legal team has recently been involved in?

Regulatory: We advise upon all applicable regulatory requirements facing our business, including recently the EU AMLA/D/R package, UK Consumer Duty, EU PSD2 consultation and corporate sustainability directive. We have supported several completed and ongoing significant regulatory examinations involving our home and host EU regulators, chiefly focusing on AML related matters. These matters focus on addressing regulatory expectations and findings in a proactive manner that balances managing regulatory requirements and relationships with Western Union’s business operations and service to its customers. We also support compliance, the business and operations on the regulatory aspects of new or changing product offerings, such as our digital wallet and retail hubs. We constantly look for ways to improve the customer’s experience of our compliance controls, while continuing to meet our regulatory requirements.

Privacy/IP: Our team operates on a global basis to protect the personal data entrusted to the company, to maintain the trust of our customers, and to comply with the rapidly-evolving global privacy legal landscape. We work closely with all business units globally to embed privacy by design principles and continuously work to enhance our privacy risk assessment processes and awareness training. As a small team with a broad remit, we think strategically and have created innovative privacy toolkits to support the wider legal team and to increase efficiencies. We have successfully handled a number of privacy regulatory matters before data protection authorities across the globe. We also manage a global portfolio of IP.

Corporate governance: The team handles the company corporate obligations of Western Union’s subsidiaries across EMEA and APAC and develops governance frameworks to support subsidiary boards of licensed entities in discharging their oversight duties. The team also works on the implementation of restructuring and M&A projects. A key project for the team in 2022 was the initial closing of the sale of Western Union Business Solutions (WUBS) for $910m.

Product: The product team is a small global team tasked with guiding our business in bringing new products to the market, a critical component of Western Union’s Evolve 25 Strategy which aims to expand our core retail and digital offerings to an omnichannel customer ecosystem. Our remit is very broad and covers everything from commercial contracts, privacy, marketing to IP, regulatory and beyond while relying on legal subject matters experts for support. We work across stakeholder groups and own the end-to-end legal journey of our products, notably including the recent launch of our European Digital banking app. We continue to help drive similar launches in other jurisdictions across the globe.

What has been the number one challenge that has impacted you over the past year?

As company strategy has evolved towards a customer ecosystem of financial products and services, we are focused on speed to market in executing new product initiatives, as well as making meaningful improvements to our customer experience while remaining compliant with our regulatory obligations. This occurs across a complex group structure and evolving regulatory landscape where we work across functions with many stakeholders.

From a privacy perspective, evolving regional data transfer laws and regulation presented opportunities to enhance our records of processing and put in place new, enhanced standard contractual clauses as well as a new intercompany data transfer agreement.

Has the increasing consciousness of climate change and sustainability affected your company and the team’s priorities, and if so how?

Western Union has published an ESG report for some years demonstrating its prioritization of this area: https://corporate.westernunion.com/esg /. In terms of team priorities, we gathered all current and downstream ESG reporting requirements applicable to relevant group entities and are supporting compliance implementation initiatives. We have also helped reduce environmental impact through data minimisation, storage limitation and use of cloud facilities over physical data centres.