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Western Union EVP Caroline Tsai: “Gender diversity has to be a target, a KPI that is measurable with clear metrics aligned against it.”

An interview with Tyler Gallagher


Companies must ensure that hiring and promotions are fair and senior leaders must champion diversity and inclusion. Gender diversity has to be a target, a KPI that is measurable with clear metrics aligned against it. Western Union is a globally diverse company, and we strive for diverse slates and interview panels both internally and externally in our recruitment practices. We’ve also started piloting gender neutral presentation of resumes and candidates.

I had the pleasure of interviewing Caroline Tsai, Executive Vice President, General Counsel and Corporate Secretary for Western Union and a member of its executive leadership team. Tsai is responsible for the overall strategic leadership and oversight of Western Union’s global legal affairs, compliance and corporate secretarial functions. Tsai also oversees the global public policy team, the Western Union Foundation, ethics and privacy functions. Prior to joining Western Union, Tsai was Deputy General Counsel and Chief Regulatory Officer at BMO Financial Group. While at BMO Financial Group, Tsai advised on advocacy and policy initiatives, as well as all bank regulatory and supervisory issues for BMO’s global operations, including Personal and Commercial Banking, Wealth Management and Capital Markets. She also served as Chief Legal Officer, U.S. Personal and Commercial Banking at BMO Harris Bank. Earlier in her career, Tsai served as Senior Vice President & Associate General Counsel at Bank of America Corporation (BAC) where she was responsible for a broad range of issues, including litigation, bank regulatory matters, the CFO Group and Global Banking and Markets. She began her legal career at the global law firm, Jones Day specializing in complexed structured transactions for investment banking clients. Tsai is a strong champion for diversity and inclusion and formerly served as Co-Chair of the Women’s Leadership Network of the National Asian Pacific American Bar Association. Born in Sao Paulo, Brazil, Tsai is the daughter of Chinese immigrants. She earned a Bachelor of Arts degree from the University of Michigan and a juris doctor degree, magna cum laude, from The American University, Washington College of Law and served as Executive Editor of The American University Law Review.


Can you tell us the “backstory” about what brought you to the Banking/Finance field?

My time spent in three financial services companies over the past 14 years has shown me the business of banking, payments and global money transfer from a customer, business, investor and regulator perspective.

I started out as a deal lawyer, structuring transactions for large investment banking clients. This was pre-crisis. From there, I was recruited to go in-house with one of my clients — Bank of America Corp (BAC). In my almost nine years there, my role covered everything from structuring very complicated capital mitigation and tax deals, to running BAC’s $100bn credit card securitization program, to Dodd Frank rule-making on Capitol Hill, to managing investor relations issues during the crisis, to navigating the litigation portfolio that we acquired through several large acquisitions.

From Bank of America, I moved onto BMO Harris Bank where I was Chief Legal Officer for U.S. Personal and Commercial Banking. My role involved navigating a significant litigation portfolio, leading the $9bn acquisition of the GE Transportation Finance business, and building out a robust compliance and risk management framework.

In my subsequent role as Deputy GC at Bank of Montreal, I was responsible for managing all regulatory and supervisory issues for our global business in North America, Asia and Europe for capital markets, wealth management, retail, commercial and business banking.

At Western Union, I’m building on my financial services experience by expanding into the Money Services Business (MSB) industry, which has very complex regulatory issues serving the unbanked population in addition to the banked and is very fintech-focused. It’s the most complex and global business I’ve ever covered but what’s positioned me to embrace it and to provide good guidance is the fact that I like complexity. I’ve had years of dealing with regulatory, product and business complexity — I see this role as another opportunity to leverage those experiences.

Are you working on any exciting new projects now? How do you think that will help people?

My current role is the most enjoyable and the most complicated job I’ve ever had. I have overall responsibility for the Legal, Compliance, Public Policy, the Western Union Foundation, Privacy and Ethics functions at Western Union. As a global payments’ provider, doing business in more than 200 countries and territories, the expansive scale and scope of our global operations means navigating a complex regulatory and compliance landscape. We deal with a wide range of policy issues, ranging from consumer protection to AML, fraud, security, and privacy. We are part of an industry that is looking to blockchain and Artificial Intelligence — it’s a very exciting time in the payments space.

We are currently working on a number of cross-industry collaboration projects in the area of financial crime compliance. In the past five years, we have spent over $1 billion to build a best-in-class compliance program. Western Union recently announced an impactful collaboration with IBM, Stop the Traffik, Europol, Barclays, Lloyd’s Banking group and others to unveil the first ever international data hub to facilitate the exchange of information about human trafficking across organizations. The Traffik Analysis Hub uses Watson Natural Language Understanding to facilitate this flow of information. Since 2013, our Financial Intelligence Unit has contributed to the detection and prevention of human trafficking, having been involved in more than 1,400 investigations, resulting in hundreds of arrests and the rescue of hundreds of victims. We are strong believers that adopting a multi-agency approach is the most effective path to take to tackle the exploitation and trafficking of people.

Western Union is also a founding member of the United for Wildlife Financial Taskforce, a group of organizations committed to the global fight against the Illegal Wildlife Trade (IWT), the annual value of which recent estimates place as high as $20 billion. I had the pleasure of representing Western Union at a private meeting on countering IWT, chaired by His Royal Highness Prince William, Duke of Cambridge, and Lord William Hague of Richmond, at the World Economic Forum in Davos earlier this year. The Taskforce is seeking to understand the challenges associated with disrupting the trade’s illicit financial flows and to explore specific actions that could be taken by the financial sector to achieve tangible reductions in IWT activity. IWT is organized crime on a global scale and it is imperative to detect, deter, prevent and report the proceeds of any such illegal activity flowing through our systems.

What do you think makes your company stand out? Can you share a story?

One of the reasons why Western Union attracted me was the value it places on financial inclusion and its impact in the community. Our omni-channel strategy is inclusive: we give our customers — many of whom are migrants sending money back home to support family and friends — more avenues to send and receive money. In fact, we are uniquely positioned to build bridges that connect people who are digitally advanced with those in the world who are not yet online.

Personally, as an immigrant myself, Western Union’s mission and the impact it makes resonates with me particularly. I was born in Sao Paulo, Brazil and grew up in Queens, NY. As the oldest siblings, my parents — who were born in Shanghai and Taipei — did not have the opportunity to attend college. My parents taught me grit and resilience and the power of education. They immigrated to two countries without knowing the language. I am proud to work for a company that powers a full range of options to serve a broad spectrum of consumers. We enable social mobility by helping individuals, communities and businesses grow through access to technology, education, resources and funds. Our customers’ success powers the global economy and we are proud to support them.

Of course, despite the progress, we still have a lot more work to do to achieve parity. According to this report in CNBC, less than 17 percent of senior positions in investment banks are held by women. In your opinion or experience, what 3 things can be done by a) individuals b) companies and /or c) society to support this movement going forward?

Women at the C-Suite level need to mentor and sponsor women in their companies. In 2015, our CEO, Hikmet Ersek, created an all-female senior advisory group with the mandate to create an action plan to promote women’s success at Western Union, through recruiting, mentoring, promoting, and measuring progress. We took the opportunity to look more deeply at our gender numbers and, although we rate as better than average, we are aiming to be high-performing in terms of gender equality at the highest levels of our company — that target is 40%. In our research, we found that often the root cause is not in hiring or retaining women, but rather in promoting women into new and expanded roles. A host of reasons contribute to this — one example being women not putting up their hands for challenging roles and, concurrently, not always being top of mind when nominations are being considered for promotion. To that end, I would urge individuals — in this case, women themselves — to actively seek out stretch assignments and seize the opportunities they present.

Companies must ensure that hiring and promotions are fair and senior leaders must champion diversity and inclusion. Gender diversity has to be a target, a KPI that is measurable with clear metrics aligned against it. Western Union is a globally diverse company, and we strive for diverse slates and interview panels both internally and externally in our recruitment practices. We’ve also started piloting gender neutral presentation of resumes and candidates.

The next step is to ensure that our executives are held accountable. A key focus for our Executive Team in recent years has been making our senior leaders champions of diversity, to inspire diversity of thought, reflecting our customer base. It starts with our leadership and manifests throughout our global workforce and our Board. Our Board includes three women and three ethnically diverse directors, with half of committees of the Board chaired by women. They are actively engaged in reviewing the women in leadership practices throughout the year.

None of us are able to achieve success without some help along the way. Is there a particular person who you are grateful towards who helped get you to where you are? Can you share a story about that?

I have had the good fortune throughout my entire career in always having amazing bosses who have ended up not only being my mentors but my sponsors. I worked hard but I also worked for individuals who pushed me to always go the extra step — they gave me the visibility in the early days and that has played a significant role on my career. I regard my former bosses, mentors and sponsors as my own personal board of directors, with whom I remain in regular contact and brainstorm frequently, from whom I seek guidance and opinions when needed. I feel very lucky to have had these people in my life.

Can you please give us your favorite “Life Lesson Quote”? Can you share how that was relevant to you in your life?

You miss 100% of the shots you don’t take. Women need to be comfortable taking stretch assignments, taking smart risks and developing and empowering women on our own teams to just go for it. You can’t succeed or move forward unless you try.

You are a person of great influence. If you could inspire a movement that would bring the most amount of good to the greatest amount of people, what would that be?

To circle back to what I said on what first attracted me to Western Union, I would say financial inclusion, and to go a step further, more inclusive innovation that offers a full range of options to serve a broad spectrum of consumers.

The World Bank makes the case that the international rise of cashless commerce threatens to marginalize too many consumers in emerging markets — an estimated 2 billion adults globally who do not have access to a transaction account that can be used to receive payments and make deposits.

Western Union offers digital services that still pay out in cash throughout some of the most remote parts of the world — the last mile so to speak. Pairing our digital network with our retail, account and mobile wallet pay-out presence allows us to serve customers using their choice of digital or cash. Our systems are also designed so that customers at any level of financial experience can use any channel they like, be it digital or cash, online or offline.

In the online environment, there are entire communities of people across the globe who want greater access to the global e-commerce marketplace but have either a need or a preference to pay in local currency; payment can be a huge obstacle. That is why Western Union has created systems enabling tens of millions of consumers across Asia, Africa and South America to shop Amazon.com globally and pay in person in the local currency. This is also why, in Kenya, we are collaborating with Safaricom, a mobile network operator, to offer its 23 million largely unbanked M-Pesa mobile wallet users the ability to transfer money globally from their phones to be paid out at a Western Union Agent location, of which we have 550,000 globally. A future with more payment options and more consumer choices is a future of vastly expanded opportunities that can bring a great amount of good for the world’s people and businesses.

Thank you so much for joining us!


About the Author:

Tyler Gallagher is the CEO and Founder of Regal Assets, a “Bitcoin IRA” company. Regal Assets is an international alternative assets firm with offices in the United States, Canada, London and United Arab Emirates focused on helping private and institutional wealth procure alternative assets for their investment portfolios. Regal Assets is an Inc. 500 company and has been featured in many publications such as Forbes, Bloomberg, Market Watch and Reuters. With offices in multiple countries, Regal Assets is uniquely positioned as an international leader in the alternative assets industry and was awarded the first ever crypto-commodities license by the DMCC in late 2017. Regal Assets is currently the only firm in the world that holds a license to legally buy and sell cryptos within the Middle East and works closely with the DMCC to help evolve and grow the understanding and application of blockchain technology. Prior to founding Regal Assets, Tyler worked for a Microsoft startup led by legendary tech giant Karl Jacob who was an executive at Microsoft, and an original Facebook board member.

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