I'm curious to know what others are doing in these situations. We had a customer file a claim of ACH fraud for a phone payment to a credit card. We have the name of the person that the credit card belonged to. Of course, it's highly likely that this person is not the person committing the fraud. In this case, it was $7,500.

Are you filing and reporting the name of the person whose credit card it was applied to or not filing as the $25,000 threshold was not met and claiming the suspect is unknown?

In these cases I file and name the beneficiary as the suspect. If our case ends at a single (or multiple) person who appears to have benefited, we label them as a suspect, considering them either a fraudster or a money mule, witting or unwitting. I agree that in most of these cases they are a victim, but for consistency if we don't have evidence that that's the case, we file and let law enforcement sort it out.

I'd add an "amen" to ColoradoAML's response. Whether victim or actual fraudster, your info points to the individual you believe benefited from the transfer.

If you can't accept naming that individual as the subject of the SAR (remember, you aren't tagging anyone as a "suspect," since that's law enforcement's responsibility), you should still file, even for $7,500, to get this on LE's radar screen. Then make sure to identify that person in the narrative so LE at least has that info to work with.

Thanks all!