People throughout the world have used mules since 3000 BC to safely move all types of precious cargo from Point A to Point B. Today, criminals throughout the world use human money mules to safely move stolen money from Point-A (victim banks, businesses, and individuals) to Point-B (criminal organizations engaged in various fraudulent schemes).
Moving stolen money in the age of digital banking is the final and most-important step for criminals cashing out of fraudulent schemes. Criminals recruit money mules with promises of easy money and easy work. The easy work involves simply using a computer to move funds into and out a money mule’s online bank accounts. The easy money is a cut of the money they transfer. It’s a work-from-home, get-rich-quick job that’s too good to be true, unless you’re a criminal.
If you receive thousands of dollars in unknown deposits into your bank accounts, and then move those unknown funds to other accounts or money transfer services such as Western Union, you might be a money mule. There are three broad categories of money mules:
- People who know that they’re criminal money mules (a/k/a witting money mules),
- People who don’t want to know that they’re criminal money mules (aka willfully-blind money mules), and
- Naive people who are clueless, unintentional money mules (a/k/a unwitting money mules).
Witting money mules are people who know that they are aiding and abetting the transfer of stolen money from bank and identity fraud victims to criminal syndicates. Criminal money mules typically open new bank accounts for the sole purpose of laundering stolen money, and also use existing accounts for money laundering. To reduce risk of arrest, sophisticated money mules often use stolen and synthetic identities to open new bank accounts. Criminal organizations pay criminal money mules a percentage of successfully transferred stolen funds.
Willfully-blind money mules are people who turn a blind-eye to the legality (or illegality) of their participation in moving money. These ’deliberately-ignorant money mules’ just want to get paid for their money-moving services. They don’t care about the harm to victims or the profits they are moving to criminal syndicates, so long as they get their cut of the stolen money. Willfully-blind money mules face possible poetic justice though, because: 1) they are subject to the same federal prosecution and prison-time for money laundering as their more complicit brethren, and 2) they may get scammed out of payment for their services, a frequent outcome for their unwitting brethren.
Unwitting money mules have no clue that they are involved in money mule activity. These are people who genuinely believe profitable, lawful money-moving business opportunities exist for individuals and small businesses; or that some poor soul or online soulmate needs money transferred for an emergency. Naive money mules frequently discover after-the-fact that criminals don’t pay their naive “marks.” Worse, they may suffer financial losses from bank chargebacks and other fees; and they can be barred from even opening new bank accounts in the future. They are typically very surprised when federal law enforcement agents contact them and start asking questions about their accounts.
There are limited law enforcement resources for meaningfully disrupting money laundering activity facilitated by money mules. The U.S. Department of Justice’s Money Mule Initiative announcements in 2019 and 2020 reveal that only 65 defendants were charged with mule-related activities during the reporting periods and 2,900 transactions were halted.
While the results to date are unimpressive, there is no reason why the U.S. (or any country) cannot meaningfully disrupt this critical link in global financial crime. For that to happen, however, financial institutions will need to play a greater role in the detection, prevention, evidence gathering, and reporting of money mule activity.
There is existing and newly available technology (such as behavioral biometrics for mule account detection) to assist financial institutions in vastly improving detection and prevention of mule activity. Upon detecting suspected money-mule activity, banks can advise the account holders to contact customer support for additional authentication and transaction vetting. The FBI’s #DontBeAMule website is a great resource for helping account holders understand and avoid the dangers.
As financial institutions incur reputational risks from mule activity in their accounts, there are benefits that can come from disrupting that activity. For starters, criminal organizations will learn quickly to steer clear. At the same time, unwitting money mules’ accounts will be protected from financial losses. Best of all, banks can work with law enforcement to return stolen funds to fraud victims, rather than allowing criminal profiteering to persist.
About Tom O’Malley
Tom O’Mallley is a former federal prosecutor who specialized in computer hacking and identity fraud cases, and a data breach victim. He retired from a 37-year career as a prosecutor to help people protect themselves from becoming identity fraud victims following data breaches.
About Frozen Pii
Frozen Pii, LLC, operates a public service website, FrozenPii.com, dedicated to making identity protection free and easy for consumers. Frozen Pii contains information and verified links to help people protect their credit reports, federal government identity, and personal data files from criminals.
