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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Repair Windows errors before they cause bigger problemsFix Now →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Banks can reduce money-mule account openings by combining application-fraud screening, identity checks appropriate to their jurisdiction, and intelligence that connects applicants and accounts to wider payment activity. No single identity check or application signal proves that someone intends to move criminal funds. A flag should prompt proportionate review—not an automatic conclusion about guilt—because some account holders are unwittingly recruited, manipulated or coerced.
What a money-mule account is—and why identity checks are not enough
The UK government defines money muling as an individual moving proceeds of crime on behalf of criminals, sometimes for payment or another benefit. Funds may pass through personal accounts, cryptocurrency transactions or cash withdrawals and handovers. Some people knowingly take part; others may be misled, manipulated or coerced. The government cautions against using “money mule” as a label for victims of financial exploitation because it can stigmatise and dehumanise them. UK government guidance on money laundering-linked financial exploitation explains these distinctions.
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The FBI describes unwitting recruits drawn in through romance schemes or job offers, people who ignore warning signs, and people who knowingly open multiple accounts, operate funnel accounts or recruit others. A person may be asked to use an existing account or open a new one in their real name. The FBI’s money-mule guidance therefore illustrates an important limit of identity verification: confirming who an applicant is does not establish how the account will be used or whether the person is acting freely.
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Which controls help at account opening?
Application-fraud screening
Application-fraud screening is one layer banks use to prevent accounts being opened for mule activity. The UK National Crime Agency’s Financial Intelligence Unit (UKFIU) describes this practice in its February 2022 banking-sector feature. It also notes that criminals may recruit people with no adverse credit history and existing accounts without reported problems. A clean credit file or plausible banking history is not proof that an application is safe. Read the UKFIU’s February 2022 “Money mules in the banking sector” feature.
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Identity checks under applicable rules
Identity verification supports customer due diligence; it is not a standalone test for mule intent. In the UK, HM Treasury and the Department for Science, Innovation and Technology published guidance on 26 February 2026 explaining that regulated entities can use digital verification services for relevant checks under the Money Laundering Regulations. For that use, a service must appear on the GOV.UK register of services certified against the UK digital verification services trust framework. The guidance supplements, rather than supersedes, obligations under the regulations. It is UK-specific and should not be treated as a rule for other jurisdictions. See the UK guidance on using digital identities with the Money Laundering Regulations.
Payment and network intelligence
Application review has a limited view: it focuses on an applicant or account before much activity may be visible. Payment profiling can add context as funds begin to move, while industry intelligence feeds and analytics can help identify connections among accounts. These controls complement, rather than replace, onboarding checks. The UKFIU’s February 2022 feature describes the range of approaches in use. Nicola Hannan, Nominated Officer at NatWest Group, says: “Detection may be undertaken in a number of ways including inbound and outbound payment profiling, screening of industry intelligence feeds, data analytics to identify mule rings and profiling of mule activity.” The passage is descriptive; it does not prescribe a particular vendor, algorithm or required implementation. UKFIU, “Money mules in the banking sector”.
How the layers differ
| Control layer | When it can help | What it examines | Important limit |
|---|---|---|---|
| Application-fraud screening | Before or during account opening | Application-level fraud risk | A clean credit history or existing account without reported issues does not rule out recruitment for mule activity. |
| Identity verification | During customer due diligence | Whether the applicant’s identity can be verified under applicable requirements | Verifying identity does not establish intent or predict every later use of the account. |
| Payment profiling | As incoming or outgoing payments occur | Payment activity associated with an account | Activity may become visible only after opening; the cited UKFIU material does not give a universal threshold. |
| Industry intelligence feeds and analytics | During screening and ongoing detection, depending on implementation | Intelligence and connections that may help identify mule rings | The cited material does not specify a required feed, vendor, model or performance level. |
This comparison reflects the control categories described by the UKFIU; it is not a performance ranking or a universal implementation standard. UKFIU banking-sector feature.
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How to handle a flag without treating it as proof
A practical operating approach is to use screening to identify cases for proportionate review, then bring in the relevant identity, application and—where available—payment or network context. That is an operational interpretation of the layered controls described by the UKFIU, not a prescribed official checklist or scoring model.
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- Check the application in context. Use application-fraud screening as one input; do not treat a clean credit file or lack of prior reported problems as clearance.
- Complete applicable identity checks. Follow the rules for the jurisdiction and account type. For relevant UK checks, consult the current digital identity guidance and register.
- Assess the strength and relevance of the signal. Distinguish an indicator that warrants further examination from evidence of knowing participation. The sources do not establish a universal onboarding feature list or reliable score threshold that identifies a mule with certainty.
- Review for signs of exploitation as well as financial-crime risk. Where circumstances raise concern, consider whether the customer may be under pressure or being manipulated, and use an appropriate, proportionate escalation process.
- Continue monitoring after opening. Payment and network patterns may provide information that was not available at application time. Keep onboarding prevention and ongoing detection connected, rather than assuming the opening decision settles the risk.
The need for careful interpretation is not theoretical: the UK government lists possible signs of financial exploitation including unexplained deposits, changes in banking behaviour, new accounts, changes in cash or ATM use, and secrecy about finances. It also says these signs are not specific to money-laundering-linked exploitation. A bank should not use a single indicator or demographic profile as proof. Account restrictions or freezes can also leave victims without access to money and worsen instability, so response decisions need to take potential harm into account. UK government financial exploitation guidance.
What the available figures do—and do not—show
The UK government’s financial exploitation guidance reports several indicators of scale, but they should not be read as counts of people proven to have committed crimes:
- The National Crime Agency assesses that money laundering in the UK involves “hundreds of billions of pounds” annually; the guidance page does not specify the publication year of the underlying estimate.
- The guidance cites an estimate of over £10 billion in illicit funds laundered through UK money-mule networks each year; the publication year of that estimate is not specified in the available page text.
- More than 39,000 accounts demonstrated behaviour indicative of money muling in 2022. This is an indicator count, not a count of confirmed criminal accounts.
- Cifas and UK Finance reported that 23% of accounts bearing hallmarks of money-muling activity in the first six months of 2023 were owned by people aged 21 and under. The finding concerns reported indicators, not proof that every account holder knowingly participated.
The UK government guidance attributes the relevant figures to the NCA, Cifas and UK Finance. They demonstrate the importance of the issue, but do not validate a particular onboarding rule or score.
What is known about AI and mule onboarding?
The UK’s 2025 National Risk Assessment says current use of AI for money laundering is not fully understood and is not currently believed to be widespread. It reports private-sector and law-enforcement engagement indicating use of AI for synthetic bank-account creation, fraud and impersonation, phishing and mule onboarding, and discusses possible future misuse involving generated synthetic identities and attempts to evade anti-money-laundering defences. This is a qualified risk assessment—not evidence that AI-generated mule accounts are already widespread. UK National Risk Assessment of Money Laundering and Terrorist Financing 2025.
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What banks should not infer from the evidence
The cited sources support a layered approach across application screening, relevant identity checks, payment profiling, intelligence feeds, analytics and attention to exploitation. They do not establish a universal set of onboarding features, a validated score, a reliable threshold, comparative vendor performance or a jurisdiction-neutral legal specification. The UKFIU’s February 2022 account is a descriptive banking-sector feature, not a current technical standard. Banks therefore need to apply controls within their own legal and operational context and treat risk signals as inputs to evidence-based review, not as proof that an applicant is a criminal.
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