Unemployment /Economic Impact Payment Fraud

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Question:

FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?

Answer:

No, but it is not uncommon for a single such fraud to grow to a reportable amount when a series of such payments is totaled.