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#2246556 - 12/15/20 07:54 PM Unemployment Benefit Fraud
Jennifer Offline
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Jennifer
Joined: Dec 2014
Posts: 190
Is the $5,000 threshold for SAR filing stand for unemployment benefit fraud as well (assuming we know the suspect)?

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#2246559 - 12/15/20 09:15 PM Re: Unemployment Benefit Fraud Jennifer
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
There are no changes to SAR thresholds for COVID related filings.
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#2246631 - 12/16/20 07:48 PM Re: Unemployment Benefit Fraud Jennifer
Brandi S. Offline
Member
Joined: Jun 2020
Posts: 54
I was wondering this as well, I'm glad you posted this question. We've had quite the uptick in UI fraud particularly from Ohio Unemployment recently but not many adding up to $5,000+ per customer. We've had smaller fraudulent UI deposits within the past few weeks and we feel like we should file but I guess we hold out for now.

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#2246637 - 12/16/20 08:26 PM Re: Unemployment Benefit Fraud Jennifer
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
Remember you can file below that threshold, and may be encouraged to do so in some cases. The info. from the FDIC below, while dated, specifically notes "It is recognized, however, that with respect to instances of possible terrorism, identity theft, and computer intrusions, the dollar thresholds for filing may not always be met. Financial institutions are encouraged to file nonetheless in appropriate situations involving these matters, based on the potential harm that such crimes can produce. Even when the dollar thresholds of the regulations are not met, financial institutions have the discretion to file a SAR and are protected by the safe harbor provided for in the statute."

FDIC SAR Info.
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#2246638 - 12/16/20 08:38 PM Re: Unemployment Benefit Fraud Jennifer
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The fact that the fraudsters took advantage of the HUGE security gaps around UI claims at a time when millions of Americans were out of work and had legitimate reasons to file and that the fraud has meant ridiculous delays in processing legitimate claims would justify in my mind setting a lower in-house trigger amount for filing SARs for this type of fraud. That said, I'm not in a bank and not affected personally by the extra work that might entail, so ....
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