As with any payment network, the ACH Network sees its share of fraudulent transactions. Fraudsters have set their sights on complex schemes that utilize Account-to-Account (A2A) transfers to funnel laundered money. Scenario One: The Mule Convinced she is in love with someone she met through an online dating website, Jane agrees to accept deposits […]
On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. In our first article in this series, we distilled the guidance down to its three component parts governance/culture, risk management, and reporting. In this article, we cover the two central components of a compliant fraud risk management program. These are […]
Part 1: Governance, Operations, Management Introduction On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. The OCC guidance can be broken down into three components: Governance/Culture Ethical standards and employee accountability. Risk Management Operations Policies, procedures, processes, controls, personnel sufficient to identify, measure, monitor, and […]
