because if it is fraud they have likely been coached on not approaching the bank if the funds are not available as they should not draw attention to the fraudulent activity.

Ditto

We consider our customers subjects too. The FBI's money mule guidance made it clear that it's a crime to be a mule whether you're witting or unwitting. It can be law enforcement's decision whether or not the person should be prosecuted.

Arkansas is ADWS and not AK (Alaska)

the identifier for Louisiana is LDOLUIBEN

How this is still an issue kind of surprises me, yet doesn't at the same time. It's a well known enough issue that you'd figure by now every unemployment agency in every state would be taking extra precautions to verify applicant info.

agreed PQ, yet we see new items coming through daily. heck, we are still getting fraudulent ones from Washington, where it essentially started...

Washington has RECOVERED over $300 million, and they still have a likely loss of at least that amount.

I am sorry if this question has been asked already but, can we return these ACH credits if we are sure they are fraud?

We have a customer who we cannot determine is willingly or not a mule for these scams. We have filed a SAR. She has already received ACH credits from STATE OF ARIZONA BENEFITS and NCDOR (NORTH CAROLINA DEPARTMENT OF REVENUE) and now has a very large one pending from IDES (ILLINOINS DEPARTMENT OF EMPLOYMENT SECURITY). Each one has a different persons name. I would very much like to return this most recent ACH that is pending.

If the name does not match, you can return an ACH. The real question is why is the account still open.

Well, we were giving her the benefit of the doubt that she did not know what she got into and realized she was being scammed and it would stop but, now that we got this one, it's outa here!!!

Thanks!

We are returning them. I agree with Randy, they would be a noncustomer at our bank.

Hey bcompliance, what return reason code do you use to return an ACH credit like this?

R03 Return Code – No account or unable to locate account

The account number structure is valid and it passes the C heck digit validation, but the account number does not correspond to the individual identified in the entry, or the account number designated is not an existing account.

ok, new question...if these ACH credits are a week or two old, can they be returned still? If they cant, how can we get these funds back to the states that issued them (ODJFS-Ohio ad State of Airzona)?

since I asked my first question I have another customer with the same deal but she wants the money sent back, doesn't want to have anything to do with them.

At the request of the customer, I think it is R23. I would verify that and get the request in writing.

Other than that, there is no much you can do.

In my 725 years of so of dealing with ACH, I have yet to hear of any Originator or ODFI that refused a credit return item as "untimely". Happens daily with debits, but never with credits. If the funds are in the account, by all means, return. So, if you identify them as fraudulent based on your own research, return R03. if the customer confirms they are suspicious and wants them returned, R23. Both technically have the 2nd business day return timeframe, but that would be the least of my concerns.

I thought you had 2 days on a R23 from when the customer notified you?

yes it is within 2 days notice from customer...my point was even if after 2 days, no originator or ODFI would refuse