Money mules move the proceeds of crime

On 16 October 2025, the Minister for Home Affairs, Mr Tony Burke, signalled intent to introduce a new power enabling the Australian Transaction Reports and Analysis Centre (AUSTRAC) to restrict or prohibit certain high-risk products such as crypto ATMs, services or delivery channels. In welcoming the announcement, AUSTRAC Chief Executive Officer, Mr Brendan Thomas, specifically referenced an "unacceptable risk of money laundering across some channels" and detailed how AUSTRAC's Crypto Taskforce established at the end of 2024 highlighted the prevalence of scam victims and money mules who had been tricked or coerced into moving money. 

Mr Thomas's statement brings into sharper focus the use and widespread prevalence of money mules. A money mule, either knowingly or unwittingly, is someone who receives money obtained through illegal or criminal activities and enables the funds to be moved to another account, typically offshore. Often, money mules are the reason why many scam victims never see their funds returned and why many criminals evade identification and arrest by the authorities as they facilitate the rapid movement of funds and obfuscation of their original source.

Recruitment of money mules

Criminals recruit money mules or establish mule accounts through a mix of deception, pressure and the promise of financial gain. Fake job ads through social media including reference to being a financial assistant or payment processor that involve applicants receiving and forwarding funds are common methods. Romance scams and other online relationships that evolve into requests to move money or open new accounts also remain a persistent source.  

International students and non-permanent residents have been identified by Australian Border Force, the Australian Federal Police and AUSTRAC as being particularly vulnerable to recruitment as money mules. AUSTRAC has detailed how international students can be recruited through opportunities to earn money while studying, while other money mules exploit student visas and are sent to Australia with no intent to undertake studies. Complicit small businesses also provide the semblance of company structures, payroll functions and other credentials to create accounts that can be utilised for mule activity. 

Importantly, not all mules are the same. Some act knowingly, moving funds for personal benefit or selling access to their accounts via social media or in the case of some international students when they leave Australia, opening accounts under criminal direction. Others are drawn in unknowingly, believing they are doing casual work, helping a partner, or completing an internship-style task. While this latter group of individuals still contributes to serious harm, mitigation efforts can be successfully directed at building awareness and education, enabling prompt intervention to freeze accounts and prevent further victimisation and safe exit from criminal schemes.  

Steps to minimise the impact of money mules 

In financial services, regulatory scrutiny around money mules is intensifying, and entities that fail to detect, report and mitigate mule activity risk reputational damage, compliance breaches, and enforcement action. Key steps that organisations can take to minimise the impact of money mules include the following:

Invest in ongoing customer and staff education   

• Anti-scam education initiatives that specifically focus on scam types commonly used to recruit money mules help tackle the issue of people being recruited unwittingly. Greater awareness of the risks engenders greater caution and helps discourage participation in schemes that sound too good to be true. 
• Embedding case studies and typology information in staff training, both at the point of onboarding and as part of annual compliance initiatives, will help frontline and operational staff recognise suspicious activity across different payment channels and identify potential mule accounts before they can be increasingly utilised to move funds.  

Strengthen customer onboarding and account opening processes   

• Electronic identity verification incorporating biometric information, liveness detection, and document validation are essential in detecting attempts to utilise stolen and/or synthetic identities from being used to established mule accounts. 
• Incorporating device identification and intelligence, internet protocol address reputation and geolocation data into risk scoring and assessment models also increases the likelihood of identifying anomalous information and potentially suspicious customer applications that may be linked to mule activity.  
• Financial services organisations routinely screen customers against politically exposed persons and sanctions watch lists. Incorporating fraud and scam intelligence, details from confirmed mule profiles and compromised identity details in regular screening initiatives further strengthens the ability to identify linkages to high-risk customers and transactions. 

Enhance transaction monitoring 

As criminal syndicates have become increasingly sophisticated in their modus operandi the effectiveness of traditional, static rule sets deployed in transaction monitoring programs has diminished. Contemporary programs can be improved by incorporating: 

• Network analysis to identify and map interactions between customers and data points, thereby identifying potentially suspicious fund flows or relationships that money launderers seek to conceal.  
• Behavioural analytics to identify deviations in customer behaviour, such as rapid changes in transaction volumes, that may be indicative of accounts being taken over or exploited as mule accounts. 
• Artificial intelligence, and specifically machine learning, to interrogate transaction data for mule typologies and the layering, structuring, and rapid dispersal of funds between accounts. 
• Integrating alert generation with case management systems to shorten review timeframes and, where appropriate, production of suspicious matter reports to AUSTRAC for intelligence purposes. Automating aspects of this process to harvest data from relevant customer profiles and banking systems will further accelerate the process and provide operational and risk teams with greater opportunity to interdict before funds are transferred on.

Deepening collaboration and intelligence sharing arrangements 

Money mules exist in a complex ecosystem and cannot be effectively tackled in isolation. Existing bodies including AUSTRAC’s Fintel Alliance and the Australian Financial Crime Exchange enable both data sharing initiatives and the exchange of tools and ideas to mitigate the use of money mules.

Private-public partnerships and cross industry exchanges are also increasingly important as they augment intelligence holdings and provide different perspectives on emerging threats and trends.

There are a range of steps banks can take to detect, report and mitigate the use of money mules and minimise their role in laundering money from scams and other predicate crimes. To find out more, please reach out at any time.