Spodek Law Group

USDA SNAP EBT Patterns Trafficking

Patterns of Irregular EBT Transactions which are considered TRAFFICKING

TYPE 1 – In a series of EBT transactions there were an unusual number of transactions ending in a same cents value.

This means that the USDA analyzes EBT transaction reports and determines that it was suspicious that so many transactions end in the same cents value. They list the number of transactions ending in x.00 and log the amounts and tally up to see how many transactions there were for each amount. They they review the merchandising prices to see if these amount make sense. The investigator visits the store, takes observations and makes notes. They check to see if the store rounds up or down to make purchases rounded to the nearest whole or half dollar. They check to see if the store promotes specials or packs that justify these patterns.

TYPE 2 – In a series of EBT transactions multiple withdrawals were made from individual benefit accounts in unusually short time frames.

This means that the same person is using their SNAP card over and over in a short time period. The USDA analyzes EBT transactions and determines the frequency with which the same EBT card is used. For example, they will find if a household used the same card on the same day, or within short periods of time ranging between 30 mins and 1 day. They use investigator observations and notes from store visits to see if the store has things that would enable high volume sales with high frequency. The absence of shopping baskets or cars, counter space, staple food items, bulk sizes, conveyor belts, or package deals makes it hard to justify large sales. The USDA assumes that multiple transactions over a short period of time, particularly when the dollar amounts are high, are indicative of trafficking.

TYPE 3 – In a series of EBT transactions, excessively large purchase transactions were made from recipient accounts.

The USDA analyzes EBT transactions and compiles a list of transactions which are “high”. The USDA determines what is high depending on the size and merchandise of the store. The USDA reviews investigator’s observations and notes from store visits to see merchandise pricing. The size of the store, the availability of shopping carts or baskets, the size of the counter contribute to the likelihood of a store making reasonable high volume transactions.