Alongside the FCA’s publication the National Economic Crime Centre (NECC) and UK Financial Intelligence Unit (UKFIU) have also supplied the following information for us to share with you.
Money Mule Account Indicators
A key mechanism to cash-out the proceeds of crime (POC) is money mule activity. Money mule activity refers to a money laundering process in which POC are moved and transferred through personal and/or business bank accounts.
Mule accounts are defined as intermediary accounts used for money laundering, acting to create complex transaction chains in order to reduce detection by the financial services sector and law enforcement of an organised crime network (OCN) and/or individual offenders.
Mule accounts might be operated by a money mule, which is a person who transfers illegally acquired money on behalf of others, knowingly or unknowingly. Often, a mule account is controlled by a recruiter (sometimes known as a herder), potentially on a temporary basis, after the account holder has provided the recruiter with their account details, bank card, pin and/or passwords in exchange for a fee.
It is worth noting that OCNs and offenders are highly likely to use a combination of different methods to obtain as many mule accounts under their control as possible.
This list covers many of the common indicators that may suggest money mule activity in accounts, transactions and other financial activity. However, this list is not definitive and criminals will be dynamic in their deployment and development of new methods.
You can read the list here
If you identify activity that may be indicative of the activity on the list, and your business falls under the regulated sector, you may wish to make a Suspicious Activity Report (SAR). If you decide to make a report in this way you should adopt the usual mechanism for doing so. It will also help our analysis if you would include the SAR Glossary Code XXJMLXX within the text if submitting on SAR online or including 0701-NECC in the alert reference number section of the new SAR portal.
To learn more about the NECC and UKFIU perspective on money mules, listen to the money mules episode of the UKFIU podcast: https://spoti.fi/3tLm3BW
Check out the latest SARs in Action magazine, focusing on how the SARs regime, Regulators and Law Enforcement have responded to the money mules threat: https://bit.ly/45RfXxo