Money Mules & AML/KYC

 Money Mule


A money mule is someone who transfers or moves illegally acquired money on behalf of someone else.

A money mule transaction is when someone transfers money on behalf of another person that was acquired illegally. Money mules are often recruited to launder money from crimes like human trafficking, drug trafficking, and online scams.

Criminals recruit money mules to help launder proceeds derived from online scams and frauds or crimes like human trafficking and drug trafficking. Money mules add layers of distance between crime victims and criminals, which makes it harder for law enforcement to accurately trace money trails.

Money mules can move funds in various ways, including through bank accounts, cashier’s checks, virtual currency, prepaid debit cards, or money service businesses.

Some money mules know they are supporting criminal enterprises; others are unaware that they are helping criminals profit.

Money mules often receive a commission for their service, or they might provide assistance because they believe they have a trusting or romantic relationship with the individual who is asking for help.

Types of Money Mules 

Unwitting or unknowing money mules are unaware they are part of a larger scheme.

  • Often solicited via an online romance scheme or job offer
  • Asked to use their established personal bank account or open a new account in their true name to receive money from someone they have never met in person
  • May be told to keep a portion of the money they transferred
  • Motivated by trust in the actual existence of their romance or job position

Witting money mules ignore obvious red flags or act willfully blind to their money movement activity.

  • May have been warned by bank employees they were involved with fraudulent activity
  • Open accounts with multiple banks in their true name
  • May have been unwitting at first but continue communication and participation
  • Motivated by financial gain or an unwillingness to acknowledge their role

Complicit money mules are aware of their role and actively participate.

  • Serially open bank accounts to receive money from a variety of individuals/businesses for criminal reasons
  • Advertise their services as a money mule, to include what actions they offer and at what prices. This may also include a review and/or rating by other criminal actors on the money mule’s speed and reliability.
  • Travel, as directed, to different countries to open financial accounts or register companies
  • Operate funnel accounts to receive fraud proceeds from multiple lower level money mules
  • Recruit other money mules
  • Motivated by financial gain or loyalty to a known criminal group

Through a process of Certification and Accreditation, an IT system can be granted an Authority to Operate (ATO)—sometimes called Authorization to Operate—a status that approves an IT system for use in a particular organization. The government uses ATOs to manage risk in their networks by evaluating the security controls for new and existing systems. Authorization certifies that the organization explicitly accepts the benefits of using the system outweigh the operational risks it introduces.

Targets of Account Takeover (ATO) Attacks

 

1.      Financial. When accessing financial accounts, an attacker can steal money or use the account to make purchases. This can be easily done with a bank or credit card account. Another option they have is to manipulate investment portfolios.

2.      Travel. A hacker can try to steal your frequent flyer miles.

3.      Retail. Hackers may try to take over online retail accounts so they can purchase products while pretending to be you and either send them to themselves or to someone else who can then sell them for profit.

4.      Government benefits. If a fraudster is able to take over an account that provides government benefits, such as Medicare, they can route the benefits to themselves or sell the account information to another hacker online.

5.      Retail loyalty rewards. Hackers can use your loyalty points rewards either for their own benefit or as an asset they can sell to other fraudsters online.

6.      Cellphone contracts. Some hackers will use your cell phone account credentials to make phone calls, send text messages, or use your data to avoid paying for it themselves.

Account Takeover


When a hacker tries to execute an account takeover (ATO), their goal is to take control of your account and use it to steal information or for their own personal profit. In the context of this account takeover definition, the end objective is typically to benefit the hacker or their organization. 

However, account takeover fraud can also be used to execute a vandalism scheme designed to hurt the reputation or the operational capacity of a company. Fortunately, there are several things you can do as part of an account takeover protection plan. All organizations, regardless of size, should have tools and protocols in place for account takeover prevention. 

AML/KYC for Money Mules

Mule accounts play a critical role in the fraud supply chain infrastructure and are a mechanism to cash out fraudulent transactions, launder money, and support criminal operations. Money mules come in many forms, each with different goals and behaviors that require unique approaches to detect. In addition to AML for AO and ATO, some softwares have features like Mule Account Detection that detects sold accounts, accomplices, and misled mules. These personas often go undetected with standard fraud detection measures.

Some Mule Operations

The account peddler

Buying and selling of established bank accounts is a common tactic for money laundering teams.

 

The accomplice

Catching the accomplice decreases illegal operations and reduces criminal growth.

 

The misled mule

Mitigating misled mules can protect financial institutions and their customers from unknowingly breaking the law.

 

Identity theft

Early detection is critical when preventing money laundering activity. 

 

Credential Stuffing

Detecting credential theft and account break ins can prevent the use of victim accounts for money laundering purposes.

Potential Consequences 

a). Money Mules

Inaccessible bank accounts – During an investigation, law enforcement officials may freeze a money mule‟s bank accounts. Being unable to access funds may create a significant financial burden. These activities may also have a long-term impact on credit scores.

Prosecution – Money mules may be prosecuted for their participation in these schemes.

Accountability for charges – In some cases, money mules are found personally responsible for repaying the losses suffered by the other victims.

Vulnerability of personal information – As described in the typical process, criminals often collect personal information from the money mules. It is possible that the criminals may use this information for other malicious purposes.

 

b). Targeted Individuals

 

If the fraud is designed to extract money from individuals, those individuals could experience the following consequences:

 Financial loss – An individual may pay for undelivered goods or have money deducted directly from one of his or her financial or credit card accounts. Depending on the forum used for the transaction and whether the scheme is identified, the individual may be able to recover at least a portion of these losses.

Significant hassle to resolve issues – Identifying and reporting the fraud may require numerous steps, and the process could take a long time

The Reserve Bank of India (RBI) said on Friday (December 6, 2024) that it has created an artificial intelligence (AI) powered model that could reduce digital fraud by helping banks deal with the increasing problem of “mule” bank accounts. The model, called MuleHunter.AI, has been developed by the Reserve Bank Innovation Hub (RBIH), Bengaluru, a subsidiary of the central bank.

The financial sector landscape, is witnessing paradigm shifts with the advent of frontier technologies. Technologies like Artificial Intelligence (AI)/ Machine Learning (ML), tokenisation, Cloud Computing hold transformative potential for the financial sector as they can handle enormous volumes of data, automate complex processes, enhance decision-making, and bring in unprecedented efficiencies.

While the benefits are many, the attendant risks like algorithmic bias, explainability of decisions, and data privacy, are also high.

Robust AML/KYC framework and continued monitoring is essential to keep Money Mules from making use of institutional networks.



Happy reading,


Those who read this, also read:

1. Other Obligations on RE under AML/CFT-RBI, India

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