Recently learned that the FI received a few unemployment insurance deposits (via ACH) which were determined to be fraudulent. Action was taken in the manner below on the previous compliance officers recommendation. Compliance officer no longer here - I am being presented with this info now.
* Account frozen - access to funds removed (account holder has not made any attempt to access funds)
* SAR filed
* Funds were removed from member account and are being held in a general ledger account
??? Question1 - What should the next step be with the funds? I don't think they should remain in the G/L. Advice on returning funds to the issuing States
??? Question 2 - I do not think law enforcement was contacted - other than filing the SAR - should we contact now?
I feel like SO MUCH MORE should have been done.