American Airlines’ Shocking Formal DOT Response; Don’t Mess With AAdvantage!

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Last year I wrote about AA shutting down accounts for creating multiple or dummy AA accounts in order to generate credit card mailers that didn’t have limits on how often you could get a signup bonus.

Historically, American has had the most vicious mileage auditors. If you sell your miles or upgrades, especially via a broker, there’s a good chance that AA will catch up with you and ban you from AAdvantage for life.

Earlier this year they shut down accounts of people who kept their miles alive via other people’s rental car receipts.

American rarely makes mistakes when they shut down accounts. Many readers have emailed me over the years about shutdowns, but in all cases they did violate the rules. Sometimes fessing up is enough to get an account reinstated, but typically it will stay closed.

When most people file a DoT complaint they use the informal complaint process. That triggers a review from a higher level airline agent than you would normally reach.

But there is another complaint avenue via a long-form formal complaint. Airlines have lawyers that respond to these formal complaints and the complaints are made public.

Here is the PDF of the formal complaint filed by Maria on April 30th.

She wrote that she used 290,000 miles for her daughter and son-in-law to fly from Miami to Maui in business class on 7/2/20. Other family members were booked on the same flight. After flight schedule changes, the family got booked on separate flights. As flights were now available for fewer miles using AA Web Special pricing, the son-in-law tried redepositing the miles in order to rebook the tickets.

Maria reveals that she voluntarily closed her AAdvantage account back in January due to “Security concerns” and that her son-in-law tried to have the miles redeposited into a new AAdvantage account. That’s a manual process that requires lots of eyes on the account and AA shut down her new account and cancelled the tickets.

She asks the DOT to order AA to return the miles and to penalize AA for their actions.

Here is the PDF of AA’s response from earlier this week and it’s the most colorful and thorough DOT response I’ve ever seen.

In it, they show just how much information they know about accounts that they shut down. AA paints a snarky and vivid picture of what happened and while some of what they respond is not factually correct, it’s still damning.

AA clearly doesn’t believe Maria is the real complainant.

“The masterminds behind this scheme appear to be the Complainant’s son-in-law and daughter, i.e., her co-fraudsters, who also violated the AAdvantage Terms…When American discovered the son-in-law’s and daughter’s fraud, it froze and then terminated their AAdvantage accounts, including several bogus AAdvantage accounts they established using fake information.”

Maria’s son-in-law and daughter are identified as known parties to the DoT as they previously filed informal complaints after their own AAdvantage accounts were shut down.

The footnotes are just as entertaining. “Like a game of whack-a-mole, the son-in-law thereafter opened yet another AAdvantage account using a phony name, which American then terminated promptly upon detection.”

AA notes that after they terminated Maria’s son-in-law’s account, she (“an email purporting to be sent by the Complainant”) requested that her account be closed.

“Unhappy that American detected and put the kibosh on the scheme, the Complainant now attempts to leverage the Department’s third-party formal complaint procedures to reinstate fraudulently accrued miles from a voluntarily terminated frequent flyer account.”

Maria later opened another AAdvantage account, to which AA sensibly notes “American maintains that the Complainant or her co-fraudsters, sensing the jig was up, changed her AAdvantage account to avoid detection by American’s corporate security department.”

Things get murkier in the next sections. American claims that Citi’s terms require waiting 48 months to get a new signup bonus, but those terms can vary based on the application language.

American says, “A small number of individuals acting in bad faith obtained invitations not intended for them– either by establishing multiple, bogus AAdvantage Accounts or getting their hands on mailers or emails addressed to third parties. Once the individual had the invitation and unique code, he or she would apply and change information during the Citi Card application process to match his or her actual identity and AAdvantage account, which otherwise would not have been eligible for a New Account Mileage Bonus. Disclosures, including those provided when accessing the online application via (as will be demonstrated in Section III, infra), clearly notified prospective applicants that only new Citi Card account holders were eligible for the New Account Mileage Bonuses.”

Granted that some people did act in bad faith to get mailers without language that required a 48 month wait, but it’s a big stretch to say that terms listed online should also apply to the mailers. And AA said earlier that bonuses could be earned every 24 or 48 months, but here they say it’s only for new account holders, which contradicts that position.

AA then cites websites like Flyertalk and Reddit where people shared tips on avoiding being audited. AA writes that these postings led them to investigate the issue and shutdown accounts.

That has little to do with this case, but I see it as a warning to others online that AA is watching them.

AA notes that the email address used to ask American to close Maria’s account is a combination of the son-in-law’s and daughter’s names and is the same email used by the daughter, but with dot aliasing.

AA reveals that Maria, her daughter, and son-in-law opened 45 Citi AA cards over 4 years and that their household opened 54 cards. Whether that’s fraudulent is open to debate, but AA makes the case that it is.

But worse for them is that the 3 of them opened 16 AAdvantage accounts in order to trigger more credit card mailers. AA only allows people to participate in offers with 1 account. This is all AA needs to win the case and avoid DOT enforcement action, but AA decided to go much deeper than this.

AA also notes that “Several of the bogus AAdvantage accounts associated with the Complainant’s son-in-law and daughter were intentionally opened under patently false first names, including “Bubbles.””

AA shut down the son-in-law’s account for fraud on 12/10/19. Maria redeemed all of the miles in her account on 12/18/19 to send her daughter and son-in-law to Maui. On 1/4/20 Maria asked AA for her account to be closed. On 1/8/20 AA shut down her daughter’s account for fraud. On 1/22/20, Maria opened a new AA account and opened another credit card and got another signup bonus.

Incredibly, that scheme seems to have worked and AA didn’t shut down her account.

But then COVID-19 hit and flight schedules were changed. The son-in-law practiced some good old HUCA and called AA 19 times to try to get the miles from that trip redeposited into Maria’s new account. Eventually that put eyes on her account and unsurprisingly, AA shut it down and voided the tickets.

AA also calls out the son-in-law and daughter as falsely filing a complaint in Maria’s name, “American has described in this Answer a number of inconsistencies between information asserted in the Complaint and information contained in American’s records. To maintain the integrity of the Department’s important procedural requirements, American respectfully requests that the Department promptly direct the Complainant to re-submit a copy of the Complaint dated April 30, 2020, with the signed verification required attached thereto.”


It seems to me that this “shock and awe” response is a warning shot from AA. File a formal complaint against us and we’ll do a deep dive into your misdeeds and air them out to the public. Complainers beware!

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26 Comments On "American Airlines’ Shocking Formal DOT Response; Don’t Mess With AAdvantage!"

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I’ve read there will be others that will be filing some more serious complaints. Meaning, they have thier paperwork in order and didn’t do anything against the T&C.

I hope they dont “settle”.


AA does keep a record of every phone call, the phone number you used, the IP used to book the ticket, the IP used to look up the ticket, the CC and email address used. If you’re trying to defraud them, you probably made a mistake somewhere.

Of course you should definitely not defraud anyone, however, AA has many false positives, and many people redeem their miles for friends and family, which triggers a cancellation/shutdown, to the point that many people just don’t want to deal with AA.


Why is American concerned at all since these are all miles they get paid (well) for by Citi?


This is Wild!

asher k

I enjoyed that. Honestly that was the most thorough response I have ever seen to a claim or complaint for anything ever. It would not surprise me if they spent more than 25 hours collecting all of that material. I am very skeptical that these AA lawyers have high hourly rates so they must have a vengeance to be so thorough.


I believe the value of the miles is worth their while


In house counsel doesn’t get paid by the hour. They get paid a salary like most people and are certainly exempt from overtime.




They should withdraw the complaint immediately and pray they don’t catch criminal charges.


I dont get it. Doesnt AA have better things to do with their lawyers than deal with this? Is something this insignificant in the overall picture of an airline really the hill they want to die on?


Good for them. I’m all for maximizing your points, but fraud is fraud.


No doubt some AA lawyers are DDF members as well…


Dan, if you did something that AA does not like, is it possible that AA would not close your account , and then void your tickets in the airport


AA Doesn’t mention a word about IP and mac address. I wouldn’t be surprised if they actually use that info but prefer not to spill all the beans, in order to help them detect more of such accounts in the future.
The homework to detect and tie all of these accounts together, probably went backwards. First they detected all of the account which were logged in to through the same computer/ ip address. Now that they have a bunch of accounts linked together they know which accounts they are after, and all they have to do is find the similarities in order to build their case.


IP and MAC are just the tip to track your computer. They have much better ways that 99.999% of us never heard of.


does hilton have the same thing that sometimes if you “fess up” they reinstate your account? i had a million hilton and was caught selling they shut my account and now it cannot be found in the system only when you contact the fraud/finance department. is there a possibility I can get it reinstated like the possibility you write sometimes with aa accounts? this has been causing me great distress the past few weeks thank you in advance


Is it worth filing now a formal complaint against El Al for the fare for the 2 (come home for Pesach) flights TLV-SFO-TLV that I bought for my son that El Al cancelled in March, or is it flogging a dead horse? Capital One World MasterCard has been less than helpful, rebilling me after 3 months of dispute, accepting El Al’s illegal claim that non-refundable fares are not covered by US law when flights are cancelled. The DOT has gotten El Al to respond but, in that they haven’t given me the refund, Cap1 is washing their hands of it & are now charging me interest on the fare, although they have waived it when I have complained. I don’t know what to do to get El Al to refund my money or Cap1 to stop charging me for flights that didn’t exist. Suggestions very welcome!


Can do something else, depends how much your ticket cost