Assess whether a provider should be suspended pending SIU (d27e33)

Situation

Bank BSA/AML case manager owns a provider should be inside a P&C carrier's auto-body network with ACH return-reason code R10 spike as the only packet. A sudden ACH origination from a previously dormant routing is what changed the clock for this Fraud Detection Claims and Benefits Fraud file.

Decision

Bank BSA/AML case manager in a P&C carrier's auto-body network must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using ACH return-reason code R10 spike after a sudden ACH origination from a previously dormant routing.

Hypotheses to test

• ACH return-reason code R10 spike reads as Remove access or reverse the item once a sudden ACH origination from a previously dormant routing is lined up to the same Fraud Detection population.
• ACH return-reason code R10 spike is closer to Temporary compensating control after a sudden ACH origination from a previously dormant routing; Remove access or reverse the item would over-claim this Claims and Benefits Fraud extract.
• Approve a documented exception is still live in ACH return-reason code R10 spike for bank BSA/AML case manager in a P&C carrier's auto-body network.
• ACH return-reason code R10 spike is missing the fact bank BSA/AML case manager needs after a sudden ACH origination from a previously dormant routing; stop this Fraud Detection close.

Analysis required

• Trace funds, counterparties, and reversals in ACH return-reason code R10 spike through the window opened by a sudden ACH origination from a previously dormant routing.
• Quantify loss if the hold is released before ACH return-reason code R10 spike is complete.
• Test a one-off dispute against the first edge of a scheme around a provider should be.
• For this Fraud Detection Claims and Benefits Fraud file, read ACH return-reason code R10 spike against a sudden ACH origination from a previously dormant routing and write the one fact that would move a provider should be for bank BSA/AML case manager.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fraud Detection / Claims and Benefits Fraud packet (ACH return-reason code R10 spike after a sudden ACH origination from a previously dormant routing). The follow-on Claims and Benefits Fraud action is what bank BSA/AML case manager does next: implement the option, assign an owner, and log the missing fact.