Assess whether to refer to law enforcement or keep civil (6755df)

SITUATION Bank BSA/AML case manager in a Medicare Advantage claims shop has one working extract — straw-buyer occupancy file — after a mule account receiving 14 unrelated payrolls in a week. If straw-buyer occupancy file cannot support to refer to law, the only defensible Fraud Detection output is hold.

DECISION Bank BSA/AML case manager in a Medicare Advantage claims shop must choose To refer to law enforcement / Keep civil using straw-buyer occupancy file after a mule account receiving 14 unrelated payrolls in a week.

HYPOTHESES TO TEST 1. A mule account receiving 14 unrelated payrolls in a week is noise around an already-controlled Payments Fraud process in a Medicare Advantage claims shop, given straw-buyer occupancy file. 2. A mule account receiving 14 unrelated payrolls in a week is the event in straw-buyer occupancy file that forces To refer to law enforcement for bank BSA/AML case manager under Fraud Detection. 3. Straw-buyer occupancy file shows a one-file miss after a mule account receiving 14 unrelated payrolls in a week, not a Payments Fraud program failure. 4. Straw-buyer occupancy file cannot decide to refer to law yet after a mule account receiving 14 unrelated payrolls in a week; hold is the only Fraud Detection close a Medicare Advantage claims shop can defend.

ANALYSIS REQUIRED 1. Check mule or round-trip markers in straw-buyer occupancy file. 2. Map typology and hold authority bank BSA/AML case manager actually has in a Medicare Advantage claims shop. 3. Trace funds, counterparties, and reversals in straw-buyer occupancy file through the window opened by a mule account receiving 14 unrelated payrolls in a week. 4. For this Fraud Detection Payments Fraud file, read straw-buyer occupancy file against a mule account receiving 14 unrelated payrolls in a week and write the one fact that would move to refer to law for bank BSA/AML case manager.

RECOMMENDATION Choose To refer to law enforcement / Keep civil on this Fraud Detection / Payments Fraud packet (straw-buyer occupancy file after a mule account receiving 14 unrelated payrolls in a week). The follow-on Payments Fraud action is what bank BSA/AML case manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fraud Detection option on to refer to law, then the evidence in straw-buyer occupancy file, then the action for bank BSA/AML case manager - Hypothesis scorecard against straw-buyer occupancy file: supported / rejected / untestable - What changes to refer to law if a mule account receiving 14 unrelated payrolls in a week is later withdrawn - Named option among To refer to law enforcement, Keep civil and the fact that kills the others