Money Mule Recruitment

This method involves persuading individuals—knowingly or unknowingly—to receive and transfer illicit funds using their personal or newly opened accounts. Criminals frequently rely on social media advertisements, job postings, direct messaging, and romance or friendship-based scam approaches to lure potential recruits. Some networks leverage dedicated “mule herders” or third-party facilitators who can quickly scale cross-border recruitment, especially targeting financially vulnerable groups and international students. Once recruited, individuals may provide existing account details—sometimes purchased from those planning to leave a country—or open new ones, allowing criminals to place and layer illicit proceeds while concealing their origins. Some participants remain unaware of their role, while others knowingly partake for perceived fast profits. If discovered, these individuals can face significant legal consequences, personal liability, and lasting financial damage.

[
Code
T0140
]
[
Name
Money Mule Recruitment
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Customer Risk, Channel Risk
]
[
Created
2025-03-18
]
[
Modified
2025-04-02
]

Mule Recruitment

Tactics

Criminals recruit money mules to explicitly circumvent KYC and compliance barriers, using third-party account credentials to establish covert entry points into financial systems and reduce direct exposure.

Risks

RS0001
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Customer Risk
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Criminals persuade individuals—often financially vulnerable or unsuspecting—to receive and transfer illicit funds, leveraging their personal or newly opened accounts. This exploits customer vulnerabilities such as lack of awareness, willingness to earn quick profits, and minimal scrutiny over personal account usage, enabling the concealment of illicit proceeds.

RS0003
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Channel Risk
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Money mule recruiters rely heavily on social media advertisements, job postings, and direct messaging to quickly and widely contact potential recruits. They exploit channels that are less monitored and can easily reach large numbers of targets across jurisdictions.

Indicators

IND02910
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Multiple IP addresses or devices used to access newly created accounts, suggesting potential external control or 'mule herding.'

IND02942
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Online or social media job advertisements promising easy income for minimal or no experience, emphasizing tasks related to receiving and transferring funds.

IND02943
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Frequent incoming transfers from disparate, unconnected parties followed by immediate or near-immediate onward transfers or withdrawals.

IND02944
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A sudden increase in new accounts opened by individuals with minimal local or employment history, closely matching known or suspected recruitment campaigns.

IND02945
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Transaction volumes or frequencies that significantly exceed the stated occupation or typical financial profile, especially if the individual is a student, unemployed, or newly arrived to the country.

IND02946
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Communication records reveal instructions to account holders on how to move funds or references to commission-based payments for receiving and forwarding money.

Data Sources

Logs authentication events, device fingerprints, and IP addresses. This data helps detect multiple or unexpected devices accessing newly opened accounts, indicating possible external control or 'mule herding,' which is commonly seen in money mule recruitment.

Collects publicly available information from websites, social media, and online forums to identify suspicious or misleading job postings that promise easy income for transferring funds, a key indicator of money mule recruitment.

Provides comprehensive records of inbound and outbound financial transactions, covering timestamps, amounts, currencies, and counterparties. This data helps detect frequent deposits from unconnected parties followed by quick withdrawals or transfers, as well as transaction volumes exceeding the customer's stated profile or occupation.

DS0033
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Provides records of known or suspected fraud, including scam patterns and reported incidents. This helps flag potential romance or social media recruitment approaches associated with money mule activities and identify accounts linked to similar fraud typologies.

Provides records of job listings, employer details, and candidate applications, facilitating the detection of sham job offers targeting individuals to receive or move illicit funds as part of a mule scheme.

Contains verified identities, declared occupations, and risk parameters. This information helps identify sudden surges of new accounts opened by individuals with limited local or employment history and flags inconsistencies between stated background and actual transaction activity.

Mitigations

Apply deeper scrutiny to accounts or customers where financial flows, social media footprints, or referral patterns suggest potential money mule involvement. Require documented proof of legitimate income sources, conduct additional ID checks, and obtain management approval before permitting high-volume or cross-border transfers.

During account onboarding, verify identities and account intentions by cross-checking applicants' stated purposes for the account with reliable documents and data sources. Investigate any indirect references to job offers or third-party use of the account to detect potential mule recruitment before activation.

Refine rules to detect money mule patterns, such as newly opened or low-activity accounts receiving numerous small deposits from multiple unrelated senders and rapidly forwarding funds to other accounts or withdrawing cash. Implement alerts for sudden spikes in transaction volume or frequency that are inconsistent with the customer’s stated profile, targeting cross-border flows and sequential pass-through transactions typical of mule networks.

Enforce multi-factor authentication and monitor login patterns for anomalies, such as multiple unique IP addresses or device locations used to access the same account. Investigate inconsistent access patterns that may indicate external "mule herders" controlling an account.

Train frontline and compliance teams to recognize red flags, such as customers who appear uncertain about the origin of funds or frequently reference third parties directing their transfers. Emphasize the detection of social media-based recruitment scripts and unusual account usage that signals possible coerced or incentivized mule activity.

Run targeted outreach campaigns via social media, email, and account login prompts to warn customers about false job ads and romance or friend-based schemes that request the use of bank accounts. Provide clear reporting channels for customers approached by suspicious recruiters.

Assign higher risk ratings to newly arrived students, financially distressed customers, or other segments commonly targeted by mule recruiters. Implement stricter monitoring thresholds for these groups, focusing on transactional velocity, cross-border fund flows, and frequent incoming/outgoing transfers indicative of mule activity.

Periodically examine public or social media sources related to new high-risk customers for job-offer postings or mentions of commission-based fund transfers. If discovered, cross-check these findings with account activities to verify if the customer is being recruited or used as a money mule.

Coordinate with law enforcement, industry consortia, and other financial institutions to exchange data on suspected mule recruiters and cross-institutional account infiltration patterns. By pooling intelligence on emerging recruitment tactics, common third-party controllers, or suspicious job advertisements, institutions can quickly identify large-scale mule networks and shut them down across jurisdictions.

Continuously update risk profiles for customers who suddenly receive or transfer funds at volumes significantly exceeding their stated financial capacity. Investigate changes in employment status, methods of account operation, and third-party involvement to identify potential mule recruitment over time.

Instruments

Criminals recruit individuals to open new bank accounts or provide access to existing ones, allowing illicit funds to be deposited under the mule’s name. The mule then follows instructions to transfer or withdraw the funds, effectively obscuring the original criminal owner. Since the accounts are legally registered to the mule, the criminal’s direct connection is concealed, enabling layering by moving funds through multiple mule-controlled accounts.

Mules are instructed to use existing cards or open new ones tied to their personal banking credentials. Criminals direct mules to receive illicit funds through these card-linked accounts and then perform cash withdrawals or make purchases. This keeps the criminal’s actual identity hidden while still enabling the rapid movement and layering of illicit proceeds.

Criminals direct mules to acquire prepaid cards or load e-wallets in the mule’s name. The illicit funds are placed onto these instruments and rapidly transferred to other accounts or converted to cash. Limited KYC requirements for certain prepaid instruments make it easier to recruit individuals, who can then unknowingly or knowingly layer funds on behalf of criminals.

Service & Products

  • Mules are instructed to open or use existing credit card accounts to handle illicit deposits, often disguised as legitimate transactions.
  • Criminals direct them to perform cash advances or fraudulent purchases, dispersing criminal proceeds and obscuring their source.
  • Mules deposit or withdraw physical cash, enabling criminals to convert illicit digital proceeds into hard currency.
  • Repetitive small transactions bypass thresholds that typically trigger enhanced scrutiny.
  • This direct handling of cash blends illicit funds with everyday cash flows, hindering traceability.
  • Criminals instruct mules to acquire prepaid cards or use existing ones, loading them with illicit proceeds in small increments.
  • Limited KYC requirements on some prepaid products reduce transparency, aiding in layering.
  • The rapid transfer or cash-out of stored values further distances funds from criminal origins.
  • Mules can receive or send illicit funds across borders under their own names, masking the true criminal beneficiary.
  • Minimal documentation beyond the mule’s identity conceals the origin of funds, complicating AML detection.
  • Rapid cross-border movement of funds facilitates layering through multiple mule-managed channels.
  • Mules open or provide existing personal accounts for receiving criminal proceeds, appearing as ordinary deposits.
  • The account holder’s legitimate profile reduces immediate scrutiny by financial institutions.
  • Subsequent transfers or cash withdrawals enable layering and concealment of the illicit origin.
  • Mules use debit cards linked to personal or newly opened accounts to receive and withdraw criminal proceeds.
  • Cash withdrawals and point-of-sale transactions quickly convert illicit deposits into everyday spending, evading centralized detection.
  • Frequent small transactions make it harder for financial institutions to trace suspicious activity.

Actors

Some illicit networks organize and streamline money mule recruitment, leveraging a broader infrastructure to:

  • Quickly establish cross-border flows of illicit funds through mule-managed accounts.
  • Provide recruitment guidance and financial instructions that obscure the true origin of criminal proceeds.
  • Exploit account holders in different jurisdictions, making it difficult for financial institutions to identify and block suspicious transactions across various regions.

Money mule herders coordinate recruitment—often using social media ads, job postings, or direct outreach—to enlist individuals as mules. They:

  • Target financially vulnerable groups or international students to scale cross-border recruitment.
  • Instruct, manage, and pay the newly recruited mules, ensuring seamless movement of illicit funds.
  • Exploit gaps in financial institution controls by distributing illicit proceeds across various accounts under different account holders.
AT0076
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Money mules are individuals—knowingly or unknowingly—who receive and move illicit funds through personal or newly opened accounts. Their actions facilitate placement and layering by:

  • Providing rapid access to legitimate financial channels, reducing initial scrutiny from financial institutions.
  • Allowing criminals to deposit illicit proceeds into multiple personal accounts, complicating transactional analysis and source-of-funds monitoring.
  • Accepting instructions to disburse funds onward or withdraw cash, further obscuring the criminal origin of the assets.

References

  1. FATF (Financial Action Task Force), Interpol, Egmont Group. (2023, November). Illicit financial flows from cyber-enabled fraud. FATF. http://www.fatf-gafi.org/content/fatf-gafi/en/publications/Methodsandtrends/illicit-financial-flows-cyber-enabled-fraud.html

  2. AUSTRAC (Australian Transaction Reports and Analysis Centre). (2024). Combating the exploitation of international students as money mules. AUSTRAC. https://www.austrac.gov.au/sites/default/files/2024-06/2024_AUSTRAC_FCG_StudentMoneyMules.pdf

  3. Moiseienko, A., Kraft, O. (2018, November). From money mules to chain-hopping: Targeting the finances of cybercrime. Royal United Services Institute for Defence and Security Studies. https://www.rusi.org/explore-our-research/publications/occasional-papers/money-mules-chain-hopping-targeting-finances-cybercrime

  4. Department of the Treasury. (2024, February). 2024 National Money Laundering Risk Assessment. Department of the Treasury.https://home.treasury.gov/system/files/136/2024-National-Money-Laundering-Risk-Assessment.pdf

  5. Rani M.I.A., Nazri N.F.S.M, Zolkaflil S. (2024). A systematic literature review of money mule: its roles, recruitment and awareness. Journal of Financial Crime, Vol. 31 No. 2, pp. 347-361. https://doi.org/10.1108/JFC-10-2022-0243

  6. Esoimeme, E. E. (2021). Identifying and reducing the money laundering risks posed by individuals who have been unknowingly recruited as money mules. Journal of Money Laundering Control. https://www.emerald.com/insight/content/doi/10.1108/jmlc-05-2020-0053/full/html