Assess whether linked accounts should be treated as one case (a05c7c)

Situation

After three applications sharing one employer EIN and no payroll, straw-buyer occupancy file is what bank BSA/AML case manager can touch in a P&C carrier's auto-body network. Fraud Detection will live with Remove access or reverse the item versus Temporary compensating control on this 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 straw-buyer occupancy file after three applications sharing one employer EIN and no payroll.

Hypotheses to test

• Three applications sharing one employer EIN and no payroll is noise around an already-controlled Claims and Benefits Fraud process in a P&C carrier's auto-body network, given straw-buyer occupancy file.
• Three applications sharing one employer EIN and no payroll is the event in straw-buyer occupancy file that forces Remove access or reverse the item for bank BSA/AML case manager under Fraud Detection.
• Straw-buyer occupancy file shows a one-file miss after three applications sharing one employer EIN and no payroll, not a Claims and Benefits Fraud program failure.
• Straw-buyer occupancy file cannot decide linked accounts should be yet after three applications sharing one employer EIN and no payroll; hold is the only Fraud Detection close a P&C carrier's auto-body network can defend.

Analysis required

• Trace funds, counterparties, and reversals in straw-buyer occupancy file through the window opened by three applications sharing one employer EIN and no payroll.
• Quantify loss if the hold is released before straw-buyer occupancy file is complete.
• Test a one-off dispute against the first edge of a scheme around linked accounts should be.
• For this Fraud Detection Claims and Benefits Fraud file, read straw-buyer occupancy file against three applications sharing one employer EIN and no payroll and write the one fact that would move linked accounts 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 (straw-buyer occupancy file after three applications sharing one employer EIN and no payroll). 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.