UK FCA findings on money mule activity and cashing out of fraud proceeds

The UK Financial Conduct Authority (FCA) has published findings from a multi-firm review on money mule activity (a form of money laundering in which a person transfers or receives criminal funds on behalf of others) and the cashing out of fraud proceeds. The review drew on a survey of 35 firms and analysis by an industry working group of 22 firms.

Key findings include:

• Retail banks accounted for most transactions passing through mule accounts, whereas other firms experienced lower volumes but higher-value transactions.
• Card payments were the most common cash-out method, as they can resemble legitimate consumer spending and are a versatile route for dispersing and monetising fraud proceeds.
• International and crypto cash-out methods were typically higher in value, showing that mule activity was not confined to UK payment flows.
• Repeat mule accounts suggest organised criminal infrastructure rather than an isolated or opportunistic misuse, as some accounts had been used multiple times for mule activity before firms shut them down, and there were accounts across multiple scam and fraud types.

The FCA expects firms to review their controls for detecting, preventing and disrupting money mule activity and to strengthen them where necessary. Firms should consider indicators beyond the initial receiving account, including linked accounts, payment characteristics and the broader transaction context. The FCA also highlights the importance of information-sharing, including through the provisions available under the Economic Crime and Corporate Transparency Act 2023, and is working with the National Economic Crime Centre to issue a further alert providing additional details of the working group's findings.

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