FCA Money Mules Review: Closing Accounts Is Not Enough

What's this about?

The FCA's latest review of money mule activity sends a clear message to regulated firms: identifying and closing suspected mule accounts remains important, but it is not enough on its own. Criminal groups continue to move fraud proceeds through chains of accounts before cashing out, meaning firms must focus not only on detecting mule accounts, but on disrupting the wider networks behind them.

Our Financial Services Regulatory Partner, Ben Cooper says...

"The FCA's review shows that offboarding suspected mules is necessary, but not sufficient. Firms need to identify and disrupt criminal activity earlier, make better use of intelligence-sharing and understand how funds move through the wider payment ecosystem. Those that view this as a narrow compliance exercise risk both regulatory scrutiny and continued financial crime exposure."

The points not to miss...

1. Offboarding is rising, but criminal networks remain active

3. Card payments remain a significant cash-out route

4. The FCA expects firms to make greater use of information-sharing powers

5. Cross-border payments and crypto remain higher-risk cash-out channels

6. Traditional assumptions about mule demographics are becoming outdated

7. Non-personal accounts are an emerging area of concern

8. The FCA has highlighted declining National Fraud Database filing rates

9. Risk exposure differs significantly between firms

10. Supervisory scrutiny is likely to increase

What firms should do now

In light of the FCA's findings, firms should consider whether:

• transaction monitoring controls can identify suspicious activity before funds move through multiple mule accounts;
• monitoring frameworks adequately capture mule-related card payment behaviours;
• customer risk models reflect changing demographic trends;
• National Fraud Database and Cifas reporting processes are operating effectively;
• ECCTA information-sharing powers are being used where appropriate and the firm has a clear framework for sharing and receiving intelligence; and
• governance and oversight arrangements provide sufficient visibility of emerging mule typologies and cash-out methods.

Our view

The review reinforces a broader regulatory trend. The FCA increasingly expects firms not only to identify financial crime risks, but to demonstrate that their controls are effective, proportionate and capable of adapting to evolving criminal methodologies.

For many firms, the most significant message is not the volume of mule accounts being identified, but the continued emphasis on intelligence-sharing, network disruption and proactive risk management. Firms that use this review as an opportunity to test and strengthen their anti-mule framework are likely to be better placed when supervisory scrutiny follows. As industry guidance and market practice around ECCTA information-sharing continue to mature, firms have an increasing opportunity to identify linked criminal activity beyond their own customer base and take a more proactive role in disrupting financial crime.

At a glance...

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