Money mule activity remains a significant financial crime risk, enabling criminals to move and disguise the proceeds of fraud through the financial system.
In its latest multi-firm review, the Financial Conduct Authority (FCA) examines how suspected money mule activity is evolving, how criminal proceeds move between accounts and where funds are ultimately cashed out.
The findings highlight the importance of effective transaction monitoring, timely intelligence-sharing and controls that identify suspicious activity before funds leave the financial system.
For firms, the challenge is not simply identifying suspicious accounts but understanding how criminal networks operate and ensuring financial crime controls keep pace.
Understanding Money Mule Activity and Cashing Out
The FCA’s review found that firms reported closing accounts belonging to 238,396 customers suspected of money mule activity in 2025, compared with 184,935 in 2023. While this reflects an increase in reported account closures, it does not necessarily indicate a corresponding increase in the prevalence of mule activity.
The review also identified accounts used repeatedly across different types of fraud, suggesting established criminal networks rather than isolated incidents.
A key finding concerns how fraud proceeds move through mule accounts. Although funds sometimes passed through lengthy chains, cashing-out activity was mainly concentrated between the second and fifth mule accounts, with the highest concentration at the second account.
Card payments were the most common cash-out method, ranging from numerous low-value transactions to higher-value payments to retailers and local businesses. International transfers and cryptocurrency-related cash-outs were typically associated with higher values.
These patterns demonstrate why firms need to look beyond individual transactions and consider the wider movement of funds, customer behaviour and links between accounts.
Strengthening Financial Crime Controls
The FCA’s findings reinforce the importance of reviewing whether existing financial crime frameworks can effectively identify and disrupt mule activity.
These findings are also relevant to the FCA Handbook’s financial crime requirements under SYSC 6.3.1R and SYSC 6.3.3R, which require firms within their scope to maintain proportionate systems and controls for managing money laundering risk and regularly assess their adequacy.
Firms should consider the following areas:
- Risk assessments: Do business-wide risk assessments adequately reflect exposure to money mule activity across relevant customers, products and payment channels?
- Transaction monitoring: Can monitoring systems identify suspicious patterns across incoming and outgoing payments, linked accounts and changing customer behaviour?
- Investigation and escalation: Are alerts investigated promptly, with clear decision-making, appropriate escalation and documented outcomes?
- Information-sharing: Are firms making appropriate use of available information-sharing mechanisms to help identify linked accounts and disrupt criminal networks?
- Governance and oversight: Does management information provide sufficient visibility of emerging trends, control effectiveness and areas requiring improvement?
The FCA also highlights opportunities for firms to use the voluntary information-sharing provisions available under the Economic Crime and Corporate Transparency Act 2023, where appropriate.
Firms should assess the findings against their own business models and risk exposure, strengthening controls where necessary. Increased account closures alone should not be treated as proof of effectiveness; firms should also consider whether their controls identify suspicious activity early enough to prevent funds from being dispersed
Looking Ahead
The FCA’s review highlights the increasingly interconnected nature of money mule activity and the importance of identifying suspicious transactions before criminal proceeds are cashed out.
For compliance teams, the priority is to translate these findings into practical action through effective risk assessments, robust monitoring, timely investigations and appropriate information-sharing.
As criminal methods evolve, firms need to ensure that their financial crime frameworks evolve with them.
How Complyport Can Help
Complyport supports financial services firms in strengthening their financial crime frameworks and maintaining effective compliance arrangements. In light of the FCA’s findings, several of our existing services may be particularly relevant.
- Financial Crime Assurance Reviews: Assessing the effectiveness of existing financial crime controls, identifying potential weaknesses and recommending practical improvements.
- Business-Wide Risk Assessment Support: Helping firms evaluate money laundering and financial crime risks in the context of their business model, customer base, products, jurisdictions and controls.
- AML Policies, Procedures and Controls: Reviewing and updating financial crime policies and procedures to support a risk-based approach to identifying, investigating and escalating suspicious activity.
- KYC/CDD Outsourcing: Supporting customer onboarding, customer due diligence, enhanced due diligence, ongoing customer reviews and remediation activities.
- AML Training for Staff: Delivering tailored training to help employees and senior management recognise financial crime risks and understand their responsibilities.
These services can help firms assess whether their existing arrangements remain appropriate, identify areas for improvement and develop a proportionate response to emerging financial crime risks.
Book a Meeting with a Complyport SME
To discuss how the FCA’s findings on money mule activity may affect your firm’s financial crime controls, transaction monitoring and regulatory compliance arrangements, contact us today to book a meeting with a Complyport Subject Matter Expert.
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