FCA Publishes Findings on Money Mule Activity and Cashing Out

Key developments include:

➡️ Scale of Mule Activity: FCA-regulated firms offboarded 238,396 suspected money mules in 2025, up from 184,935 in 2023, highlighting the continued scale of mule activity across the financial sector;

➡️ Cashing-Out Patterns: Fraud proceeds were usually cashed out between the second and fifth mule accounts, with the highest concentration at the second account, reinforcing the importance of detecting and disrupting mule networks early;

➡️ Organised Mule Networks: Some accounts were used repeatedly and across different fraud types, suggesting established criminal infrastructure rather than isolated or opportunistic misuse;

➡️ Evolving Detection: The FCA expects firms to consider linked accounts, payment characteristics, wider transaction context and customer information when assessing suspected mule activity; and

➡️ Information Sharing: The FCA reinforced the importance of timely intelligence sharing between firms using the available information-sharing provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA).

✅ Firms should consider the FCA’s findings against their business models, customer bases and exposure to money mule risk, and review whether their controls effectively detect, prevent and disrupt mule activity. This should include looking beyond the initial receiving account to linked accounts, payment characteristics and the broader transaction context, and using the voluntary information-sharing provisions of the Economic Crime and Corporate Transparency Act 2023 where appropriate.

💡 Plenitude conducts independent assessments to help firms assess their exposure to evolving fraud threats, including money mule networks and emerging cash-out typologies. Visit our website for more information: https://www.plenitudeconsulting.com/services/fraud-prevention-services