Fraudulent Unemployment benefits ACH

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.

The bank is not the police and has absolutely no right or power to seize funds. I would be in contact with my legal counsel at this point.

if they were deemed to be fraudulent why were they not returned to the originator?

some links that may provide assistance

https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/UIFraudReporting
https://www.justice.gov/coronavirus/national-unemployment-insurance-fraud-task-force

Wish I knew - all took place before I came here. Former CO has since retired. Thanks for the reference docs Much appreciated