Spotlight: Handling Suspect Credits in ACH


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To an experienced Operations professional, the Return options available in the ACH Network may seem pretty straight forward, but Compliance Officers often realize that their unique cases require the institution to look beyond standard Return definitions to comply with AML and Regulations. Considering the challenges institutions face in balancing ACH Rules with compliance requirements, we’ve created a course just for you both!

Did you know?
– You can refuse to allow a transfer or provide funds to a consumer if you suspect money laundering /money mule activity is involved?
– You can return suspect tax refunds, even suspect state refunds?
– Regulations and laws always supersede the ACH Rules?
– There’s more than one way to return an ACH credit?
– There’s a better option over Reversals for ODFIs to recover fraudulent credits?

If you answered “no” to any of these questions, then this course is for you!

Using actual cases involving money mules and fraudulent credits attributed to many different forms of fraud, and even synthetic identities used to open accounts, we’ll examine how to handle suspect credit entries correctly.

In this course, attendees will:
– Learn how to navigate critical provisions of the ACH Rules to ensure balance with Compliance obligations
– Discuss the Effects of Illegality
– Review Funds Availability Exceptions and what this means to ODFIs and RDFIs
– Examine the ACH Returns landscape, digging into valid return reasons using existing codes for common cases


Rayleen M. Pirnie, BCJ, AAP, CERP is the Director of Risk & Fraud at NEACH overseeing the organization’s comprehensive risk management program, advancing strategy to support both industry and member efforts to identify and mitigate fraud. With more than 20 years of experience, Rayleen is a leading expert in payments rules, compliance, risk management, fraud prevention, and security. Through leadership roles and years of research and dedication, Rayleen has developed a deep knowledge and unique skillset that allows her to deliver actionable solutions to not only financial institutions and financial service providers, but across other industry verticals as well. Rayleen is an Accredited ACH Professional (AAP) and a Certified Enterprise Risk Professional (CERP). She is a member of the Association of Certified Fraud Examiners (ACFE) and holds a Bachelor of Science in Criminal Justice Administration. She is an author and highly sought-after speaker.

Recorded on Tue, Jul 25, 2023 2:00 PM – 3:00 PM EDT


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