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Money Laundering

Money-Mule Herding & Recruitment

Networks recruit individuals, often students, job-seekers and the financially vulnerable, to open or hand over accounts that receive and forward illicit funds. A controlling herder coordinates many newly-opened accounts that share common funders or beneficiaries, rapidly moving proceeds of fraud and other crime while distancing the controllers from the money.

Firm typesBank / Credit InstitutionE-Money Institution (EMI)Payment Institution (PI)Neobank / Digital Bank
ProductsDomestic PaymentsE-Money AccountsCross-Border PaymentsCard Issuing
CustomersIndividuals
Key terms:

What it is

Networks recruit individuals, often students, job-seekers and the financially vulnerable, to open or hand over accounts that receive and forward illicit funds. A controlling herder coordinates many newly-opened accounts that share common funders or beneficiaries, rapidly moving proceeds of fraud and other crime while distancing the controllers from the money.

Control objective

Detect mule accounts and the herder networks controlling them by identifying newly-opened accounts exhibiting rapid receive-and-forward behaviour with shared funders, beneficiaries, devices or control signals.

Data required

  • Account age and onboarding details (device, IP, contact details)
  • Inbound credits, sources and the proportion forwarded onward
  • Time between inbound credit and onward transfer
  • Shared funders or beneficiaries across multiple accounts
  • Shared device IDs, IP addresses, phone numbers or addresses across accounts
  • Customer profile (age, declared occupation, expected activity) versus observed flows
  • Fraud reports, chargebacks or law-enforcement requests linked to inbound funds
  • Dormancy followed by sudden high-velocity activity