Thread Options
#2251245 - 03/25/21 05:54 PM Potential Umemployment Fraud
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,942
New York City
We have a client that had twelve ACH credits which were originated by the State of NJ - Unemployment which totaled over $6,000 (Over a two day period). Has anyone seen a similar pattern before? If so I'd be interested in hearing what your conclusions were. I'm having a hard time understanding how this could be legitimate given the number of transactions over a two day period. We've reached out to the customer but have yet to receive a response.

It's not a lot of money but it is over the $5,000 threshold which is why we are looking into it further.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
BSA/AML/CIP/OFAC Forum
#2251249 - 03/25/21 06:20 PM Re: Potential Umemployment Fraud ACBbank
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 5,964
Illinois
Have you looked closer at the ACH batch to see if all the payments are payable to your customer? A sure indicator of employment fraud and your customer being a money mule is if the payments are for "unemployed" folks who are not owners on the account. Also, does your customer actually live in New Jersey? Receiving unemployment from a different state is certainly a red flag.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2251250 - 03/25/21 06:22 PM Re: Potential Umemployment Fraud ACBbank
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 5,964
Illinois
Also, have you read FinCEN's advisory on unemployment fraud? Your situation certainly hits on a number of the red flags in that advisory.

https://www.fincen.gov/news/news-re...insurance-fraud-during-covid-19-pandemic
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2251252 - 03/25/21 06:28 PM Re: Potential Umemployment Fraud ACBbank
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,942
New York City
I did look at the batch and the customer and ACH individual names are exact matches and our customer does live in NJ. That's why I'm a confused about these transactions.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2251254 - 03/25/21 06:33 PM Re: Potential Umemployment Fraud ACBbank
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,928
TN
While I don't know a lot about unemployment - could some of these be back payments?
_________________________
My Opinions Only

Return to Top
#2251256 - 03/25/21 06:34 PM Re: Potential Umemployment Fraud ACBbank
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,942
New York City
Possibly Skittles. I did see a Unemployment payment in November 2020 for $160 and they stopped until the recent spike. I'm not familiar with how unemployment works and our Fraud Department is slammed at the moment.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2251280 - 03/26/21 12:34 PM Re: Potential Umemployment Fraud ACBbank
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 252
Here in New York, I have been seeing people getting dozens upon dozens of back payments at once triggering a bunch of alerts. Your customer is located there and the name on the ACH matches. I have been clearing these alerts unless there are other circumstances that warrant further review.

One particular case I reviewed in depth was a customer receiving payroll and UI at the same time. What I did notice is that at the time businesses were shut down here, his payroll deposits went down by about $500 a week, he was only receiving a base UI benefit of about $150 bucks, plus the $300 bonus. Partial unemployment benefits from reduced work explained this away.

Return to Top
#2251282 - 03/26/21 12:43 PM Re: Potential Umemployment Fraud ACBbank
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,701
You are here
We have a client that had twelve ACH credits which were originated by the State of NJ - Unemployment which totaled over $6,000,


Back payments (seen it in NY)
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2251283 - 03/26/21 12:50 PM Re: Potential Umemployment Fraud ACBbank
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,942
New York City
Thank you everyone.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2251304 - 03/26/21 03:37 PM Re: Potential Umemployment Fraud ACBbank
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,422
Somewhere
Ours have been customers who received back payments, and they were legit.

Return to Top
#2251324 - 03/26/21 06:36 PM Re: Potential Umemployment Fraud P*Q
mkp122 Offline
100 Club
Joined: Aug 2005
Posts: 199
NJ
Any one have thoughts on business owners of restaurants, nail salons, etc receiving unemployment? We have several customers receiving unemployment when we know their business is opened.

Return to Top
#2251328 - 03/26/21 07:15 PM Re: Potential Umemployment Fraud ACBbank
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 5,964
Illinois
They may still qualify for reduced benefits if their hours have been reduced.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2251329 - 03/26/21 07:21 PM Re: Potential Umemployment Fraud ACBbank
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,928
TN
I know my brother drew unemployment even thought his business stayed open. In order to keep the business viable and pay his employees he stopped drawing a paycheck for many months.
_________________________
My Opinions Only

Return to Top

Moderator:  Andy_Z