The role of a money mule
A money mule transfers or moves illegally obtained money for someone else. The activity can involve cash, bank accounts or virtual assets. An account used for this purpose is often called a mule account.
The term describes a role in moving funds. It does not establish what the account holder knew or whether they meet the elements of an offence.
Sources: AUSTRAC: Definition; AUSTRAC: Printed pages 28 to 29: scam proceeds and mule accounts.
Keep the person’s circumstances visible
A person may knowingly participate or may be deceived or coerced. Record the evidence for any conclusion about their role. Do not assume that nationality, age or student status establishes involvement.
Separate the sender, account holder, person giving instructions and intended recipient. They may be different people. Their relationships matter to the review.
Sources: AUSTRAC: Definition; AUSTRAC: Printed pages 28 to 29: scam proceeds and mule accounts.
Example: a supposed payment job
In a fictional case, a customer says a new employer asked them to receive and forward payments. The account activity does not match the work they describe. The reviewer records the explanation and relevant transactions.
The reviewer considers possible exploitation and the business’s AML duties. They do not describe the customer as a willing offender without evidence. Fraud support and AML review may need separate actions.
Sources: AUSTRAC: Definition; AUSTRAC: Printed pages 28 to 29: scam proceeds and mule accounts.
- Person giving instructions
Identify who asked for the transfer.
- Person moving funds
Record the account holder’s actions and explanation.
- Recipient
Identify where the funds went, where records permit.
Distinguish the people in the payment record
Illustrative review questions. The account holder may differ from the person giving instructions. The diagram does not establish knowledge or guilt.
Connected concepts. Lines do not show ownership or a reporting hierarchy.
Connect the records
Use transaction references to connect relevant payments and instructions. Keep facts separate from a proposed explanation. Apply approved escalation and information-sharing procedures. Read the fraud and SMR articles for the separate decisions that can follow.
Sources: AUSTRAC: Definition; AUSTRAC: Printed pages 28 to 29: scam proceeds and mule accounts.