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#1532953 - 04/07/11 07:39 PM
Explanation for Increase in IATs
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Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
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Is this weird? Since September 2009, our incoming IAT activity has been very consistent. In March, our debits quadrupled. Upon review, I noticed that the additional IAT debits from our customers' accounts were all initiated by the same bank, a bank that initiated hardly any prior to March. Several accounts were affected by these low dollar debits. I'd like an explanation, but maybe I'm concerned over nothing. Thoughts?
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.
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#1533195 - 04/08/11 01:36 PM
Re: Explanation for Increase in IATs
Hrothgar Geiger
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10K Club
Joined: Jul 2001
Posts: 85,417
Galveston, TX
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Small dollar amounts through paypal might signal off-shore illegal internet gambling, if these are consumer accounts.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1533201 - 04/08/11 01:58 PM
Re: Explanation for Increase in IATs
rlcarey
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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If they are micro-amounts, they could be attempts to sift out invalid account numbers or routing info from compromised data.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1533230 - 04/08/11 02:26 PM
Re: Explanation for Increase in IATs
Retread
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Power Poster
Joined: Jul 2008
Posts: 4,815
You are here
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Thanks for the link, tring to figure out what a customer is doing with PP can be a nightmare.
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#1533233 - 04/08/11 02:29 PM
Re: Explanation for Increase in IATs
John Burnett
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Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
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Yes, they are real IATs. They range from $0.30 to $200 with 61% of them <= $10 and 77% <= $25. Several different initiator names/addresses, but the same initiating bank.
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.
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#1533235 - 04/08/11 02:31 PM
Re: Explanation for Increase in IATs
Retread
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Power Poster
Joined: Apr 2005
Posts: 4,013
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We've seen them too. Almost all related to Paypal trans. Some amounts less than $5.00. For a while we would be checking with customers to see if they are legit. Nobody came back and said they weren't. All to individuals. We didn't continue to check with the customers as it became labor intensive and we were not finding any issues. Gambling? Not for these peanut amounts and I am not seeing the same purchaser/customer on any frequent basis. Interesting points made here, though.
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#1533240 - 04/08/11 02:36 PM
Re: Explanation for Increase in IATs
Trees
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Power Poster
Joined: Jul 2008
Posts: 4,815
You are here
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FWIW Purchase from Ebay are settled through Pay Pal. My wife purchases are frequently below $5.00.
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#1533256 - 04/08/11 02:47 PM
Re: Explanation for Increase in IATs
edAudit
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Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
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They all seem to be related to PayPal. Interesting that they are just now showing up as IATs after all this time.
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.
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#1534415 - 04/12/11 04:52 PM
Re: Explanation for Increase in IATs
doodles
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100 Club
Joined: May 2009
Posts: 234
hanging on by a thread
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We had never had any IATs show up on our report until March. Then, we starting having one or two a day. I investigated them all and they were all either E-bay or online purchases made using Paypal. The customers were aware of the charges, but unaware they were international.
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#1544694 - 05/03/11 04:01 PM
Re: Explanation for Increase in IATs
gacompliancegirl
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Diamond Poster
Joined: Nov 2004
Posts: 1,005
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We receive this notice from WesPay yesterday May 2, 2011 Expect an Increased Volume of IAT Transactions PayPal has launched the final phase of their IAT conversion earlier this week and members may begin to see a significant increase in IAT volume. PayPal is now fully converted and all eligible PPD and WEB transactions will now use the IAT format. As an RDFI, remember that all individuals identified in the seven mandatory IAT addenda records must be compared against the OFAC Specially Designated Nationals or "SDN" list.
Our report jumped from 1 or 2 a month to over 50 on the report yesterday. Today is back down to 15. I have a question about the report. I have always thought if the name is coded a "1" then I needed to do greater due diligence but if it was coded "o" then the gateway operator cleared the name. All the names are coming through with no number so does that mean I nave to research each name each day?
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#1545197 - 05/04/11 01:01 PM
Re: Explanation for Increase in IATs
river girl
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Although you may see reduced risk if the transaction is tagged to indicate that the GO vetted the entry, you are still responsible for OFAC compliance. The NACHA OFAC guidelines for IATs can be found in the 2011 Operating Guidelines, beginning on page OG 16.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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