I am guessing it is a formula, essentially a simple encryption. If you have enough FALs you could work it out. Credit Cards have it also but a lot more numbers. If Gun City did check it and it passed then it is either a legit number or lucky. The cipher could be as simple as for instance if your letter is "H" the first three numbers are a multiple of 8. It's possible they simply obtained a legit number from someone.
Still fraud, most smart investigators and auditors use a legal means to test a system. IE begin a transaction but don't finish it, underage alcohol and cigarette purchasers are a good example. they set up the deal but don't finish it. Out of principle you don't actually commit a crime to prove one is easy to commit. GC has also not done a good job on this but nothing like Duncan Greg and Heather.
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