Money mules: mule activity and cashing out findings
AI Analysis
The FCA published a multi-firm review on 23 September 2026 showing that firms closed 238,396 suspected money-mule accounts in 2025, compared with 184,935 in 2023, while criminal proceeds were commonly cashed out after passing through the second to fifth mule accounts. The publication is guidance rather than a new binding rule, but it signals supervisory expectations that firms improve early-chain detection, investigate linked accounts and cash-out patterns, and use lawful information-sharing to disrupt organised networks.
Key dates
- 2023-01-01
- The Economic Crime and Corporate Transparency Act 2023 received Royal Assent during 2023; its voluntary information-sharing provisions are identified by the FCA as a potential mechanism for firms to share information concerning economic crime. The specific commencement date for any relevant provision should be verified against the applicable commencement instruments.
- 2025-01-01
- Cifas introduced a dedicated funds received for money muling filing category and revised filing criteria and guidance, making 2025 filing data not directly comparable with 2023 and 2024. The date is stated as January 2025 rather than a specific day.
- 2026-09-23
- The FCA published its multi-firm review on money-mule activity and cashing out findings.
Suggested considerations
- Firms should consider refreshing their business-wide and customer-risk assessments to reflect mule-chain activity, including the concentration of cashing out between the second and fifth accounts and the higher concentration at the second account.
- Compliance and fraud teams may wish to test whether transaction-monitoring scenarios identify linked accounts, repeated use of accounts across fraud types, rapid onward transfers, fragmented card spending, international destinations and higher-value crypto-related cash-outs.
- Firms should consider reviewing controls across the full payment chain rather than focusing only on the first account receiving suspected fraud proceeds, including internal account link analysis and escalation between fraud, AML and investigations teams.
- Banks, payment institutions and EMIs may wish to compare detection and response performance by account tenure, customer type and channel, noting that 74.1% of EMI closures and 56.9% of PI closures in the survey occurred within six months of account opening.
- Firms should consider assessing whether their use of the National Fraud Database is effective and whether suspected cases meet the applicable Cifas evidential and category criteria; the FCA data should not be interpreted as requiring Cifas filings to equal account closures.
- Firms should consider whether the Economic Crime and Corporate Transparency Act 2023 information-sharing provisions can lawfully support prevention, detection or investigation of linked mule activity, with appropriate governance, records and data-protection controls.
- MLROs and nominated officers may wish to prepare for the further FCA and National Economic Crime Centre alert and retain evidence showing how the review findings were considered and, where appropriate, incorporated into control enhancements.
What changed
The FCA has provided new supervisory findings on the scale, profile and mechanics of money-mule activity based on a survey of 35 firms and analysis by a 22-firm public-private cell covering 140 cases across seven fraud types. It expects firms to use the findings in their own money-mule risk assessments and to review and strengthen controls for detecting, preventing and disrupting mule activity. The findings emphasise that monitoring should extend beyond the initial receiving account to linked accounts, payment characteristics, transaction context, customer information and subsequent cash-out activity. Card payments were the most common cash-out method; international destinations and crypto-related cash-outs were generally higher value. The FCA also highlighted voluntary information-sharing
Compliance impact
The FCA describes an evolving, organised financial-crime threat involving repeat mule accounts, early-chain cash-out and payment methods that can resemble legitimate consumer spending. Although the review is non-binding guidance, supervisory follow-up and a forthcoming FCA and National Economic Crime Centre alert mean that weak risk assessment, transaction monitoring, investigation, information-sh
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.
What the FCA said
This review highlights key trends in money mule activity.
Published by FCA . Read the full notice at the source for the authoritative text.