Suspicious Activity and ACH Transactions

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Question:

We have discovered an attempt(s) to process web-based ACH entries through our institution, but the account numbers used are invalid and appear to be randomly selected/generated. The transactions reject during ACH processing because of the invalid account numbers and are returned to the originator. The total amount involved in the activity thus far is under $5,000, and we cannot identify a suspect. Different (but similar) names are being used in the transactions and are primarily coming through what appears to be bill pay service providers. Is this activity SAR reportable?

Answer:

I recommend filing, even though you may not have reached the $5K threshold. This could become serious, and no legitimate bill-paying firm would want this going on. It looks like attempted theft from an insured bank to me.

If the bill-paying firms are known to you, you might consider contacting them to warn them of the problem and inquire into its source.

First published on BankersOnline.com 2/3/03