Assess whether a SAR narrative is supportable today (312811)

Situation

Mortgage Fraud work in a regional bank's card portfolio now turns on a SAR narrative is because a mule account receiving 14 unrelated payrolls in a week put account-takeover device-fingerprint graph in play. Mortgage Fraud work in a regional bank's card portfolio now turns on a SAR narrative is because a mule account receiving 14 unrelated payrolls in a week put account-takeover device-fingerprint graph in play; bank BSA/AML case manager should say what account-takeover device-fingerprint graph proves for Fraud Detection.

Decision

Bank BSA/AML case manager in a regional bank's card portfolio must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using account-takeover device-fingerprint graph after a mule account receiving 14 unrelated payrolls in a week.

Hypotheses to test

• Authorize Remove access or reverse the item now; account-takeover device-fingerprint graph already has the discriminator after a mule account receiving 14 unrelated payrolls in a week.
• Keep Temporary compensating control in force until account-takeover device-fingerprint graph is completed after a mule account receiving 14 unrelated payrolls in a week for bank BSA/AML case manager.
• Treat account-takeover device-fingerprint graph as Approve a documented exception because both readings appear after a mule account receiving 14 unrelated payrolls in a week.
• Refuse a Fraud Detection close: bank BSA/AML case manager does not have the page a SAR narrative is turns on in account-takeover device-fingerprint graph.

Analysis required

• Quantify loss if the hold is released before account-takeover device-fingerprint graph is complete.
• Test a one-off dispute against the first edge of a scheme around a SAR narrative is.
• Check mule or round-trip markers in account-takeover device-fingerprint graph.
• For this Fraud Detection Mortgage Fraud file, read account-takeover device-fingerprint graph against a mule account receiving 14 unrelated payrolls in a week and write the one fact that would move a SAR narrative is 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 / Mortgage Fraud packet (account-takeover device-fingerprint graph after a mule account receiving 14 unrelated payrolls in a week). If account-takeover device-fingerprint graph cannot force a Fraud Detection label under Mortgage Fraud, stop. If account-takeover device-fingerprint graph after a mule account receiving 14 unrelated payrolls in a week cannot support Remove access or reverse the item versus Temporary compensating control on this Fraud Detection Mortgage Fraud close, bank BSA/AML case manager must do not infer a control or scheme beyond the transaction and entitlement evidence.