The Central Bank of Ireland (Central Bank) has entered into a settlement agreement as part of its Administrative Sanctions Procedure with Western Union Payment Services Ireland Limited (Western Union). Western Union was fined €1.75m for breaches of the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 (CJA 2010) as it failed to demonstrate that it had robust policies and procedures in place to counteract money laundering and terrorist financing and had outsourced certain "key" anti-money laundering and counter terrorist financing compliance functions to a group entity based in Lithuania. According to a statement released by the Central Bank's Director of Enforcement, such a high fine was imposed "in light of the inherent risks in the sector in which this firm operates and by reference to the scale and geographic size of the firm’s business and its reliance on third party agents and outsourced service providers."