Prevent Money Laundering and Consumer Fraud


Walmart offers financial products and services around the world, including money transfers, money orders, check cashing, bill pay, gift cards, credit cards, and insurance. Most customers perform transactions with good intent, but some criminals attempt to use our services for money laundering or to victimize customers. Preventing money laundering and consumer fraud protects our customers and company and may stop serious crimes.

A customer refuses to provide her address for a $3,000 (USD) money transfer to another country. Should I report this customer as a "suspicious person?"

Any customer reluctant to provide the requested information should be reported as a “suspicious person” when processing financial transactions.

A customer asked me if I could split a $5,000 (USD) transaction into two transactions of $2,500 (USD) so they did not have to bother with paperwork that may otherwise be involved. Should I process the transaction this way?

No. If it’s truly the same transaction, it should be processed as one transaction and the proper paperwork should be completely filled out and turned in for reporting to the government or Walmart, if applicable. If the customer refuses to comply, contact a member of management to assist you. 

What if it is a particularly busy day, and I have a line of customers waiting. The customer at the front of the line wants to send a money transfer to an individual she does not know, and I think it might be a fraud scam. What should I do?

If you suspect money laundering or a fraud scam, follow the appropriate procedures to report suspicious and fraudulent activity in your country. If legally allowed in your country, do not complete the transaction and report it. Though this may take additional time and inconvenience the customers who are waiting, you may be preventing fraud or other criminal activity. 

A third party (potential supplier/vendor, customer) is completing the onboarding process but is not willing to share key information to complete the AML due diligence. Is it ok to make an exception?

If the third party is not willing to submit the required information to complete the AML due diligence or submits inconsistent or false information, this should be considered a red flag. It is key to properly identify and create a profile of those third parties we conduct business with to mitigate risks of facilitating transactions that could be related to money laundering or terrorism financing.

While watching the news, I realize that a supplier with whom Walmart has a commercial relationship is under a criminal investigation related to drug trafficking. What should I do?

If you are aware of information that may involve existing suppliers participating in questionable activities, it is important to raise the concern to your market AML/Financial Services Compliance team.  The AML/Financial Services Compliance team will determine next steps, which may include conducting a due diligence review to confirm whether or not the commercial relationship poses a risk for the company.

A customer is talking on the phone while trying to purchase gift cards. The customer seems to be nervous and appears to be receiving instructions from the person that she is talking to on the phone. Her behavior is suspicious, and I think the customer might be the victim of a fraud scam. What should I do?

Ask the customer if she knows the person she is buying the gift cards for and advise her that she could be the victim of a fraud scam.  Follow the appropriate procedures to report suspicious and fraudulent activity in your country.