Neil Averitt commentary: Western Union case scores a hit on civil strategy, a miss on criminal deterrence

(February 17, 2017) -- The Federal Trade Commission and the Justice Department have just wrapped up their successful efforts against Western Union for aiding and abetting fraud. These projects get a mixed report card. On the one hand, the agencies have pursued an imaginative and commendable program of cutting fraud operators off from the business infrastructure that they need. On the other hand, future deterrence has been significantly weakened by the DOJ’s unexplained failure to pursue criminal charges against the higher-level individual executives who managed the company....

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