Western Union Payment Services Ireland Limited (WUPSIL)
The licensed payment institution Western Union Payment Services Ireland Limited (WUPSIL), part of the Western Union group, is supported in its Dublin offices by a legal function staffed by three lawyers and three compliance officers led by Feidhlimidh Wrafter, vice president and head of legal and compliance, a corporate governance team of one lawyer and three paralegals, and by a wider European legal function of the general counsel’s office, led by Christopher Fischer, associate general counsel, based in Vienna. Recognising the dual importance of tailored legal advice and efficient organisational structure, Wrafter describes his team’s impact on the company as being successful in ‘managing and mitigating’ regulatory risk. Ways in which this has been achieved include several changes and innovations internally, including the establishment of a regulatory compliance function to advise and help WUPSIL departments implement regulatory compliance in accordance with legal obligations, regulatory guidance and best industry practice. A separate anti-money laundering compliance department addresses AML compliance and associated risk. Mindful of political and market-led external factors that could affect WUPSIL, Wrafter and the broader European legal team have dealt with numerous business-affecting external events within the recent past. Market risks pertaining to political developments such as the Greek bailout and Britain’s decision to exit the European Union, plus challenges connected with digital trends within the payment sector, money-laundering, cybersecurity and regulatory trends are all on the radar. The team’s approaches range from briefings and consultations with business management to advising on laws and regulations underpinning the design and implementation of sophisticated compliance programs. The Dublin-based legal and compliance teams are key advisors and report directly to the WUPSIL CEO, the board, risk and compliance committee and senior management committees. The overall philosophy of the team is described as being an ‘integral key partner in enabling revenue and helping drive strategy’.