Once the card was returned to the cardholder, the caretaker's authority ended. Subsequent uses by the caretaker should be considered unauthorized EFTs, if you determine that the cardholder's statement of facts is correct.
That leaves you with the potential that the charges in question actually benefited the cardholder. That would be your only "out," in my opinion.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8