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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

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September 14, 2020

You've Discovered a Money Mule: Who You Gonna Call?

The movie Ghostbusters is not a favorite of mine, but many people view it as a classic. While we can debate its status as a classic, there is no debate that it has one of the most well-known lines of any theme song in all of Hollywood: "Who you gonna call?"

The lyrics from this song were the recent topic of discussion among my colleagues as I shared with them that a banker had reached out to me about a fraud scheme that affected his customers. As he researched this scheme, he identified the involvement of a money mule using multiple accounts at two different banks to deposit funds from fake or counterfeit checks. His research also led him to a website that appears to be dedicated to hiring money mules to launder money. In this particular case, the banker rightfully contacted the two institutions where the fraudulent funds were deposited to inform them of the scheme and their potential money mule customer.

The banker asked, "What should I do now?" And "Who do I need to call?" After discussing with my Risk Forum colleagues, I made several recommendations to the banker about what to do and whom to contact:

  • Contact law enforcement, both the local law enforcement office and the local Federal Bureau of Investigation office.
  • File a Suspicious Activity Report with the Financial Crimes Enforcement NetworkOff-site link.
  • If your financial institution is part of the Financial Services Information Sharing and Analysis Center (FS-ISAC)Off-site link, report the money mule to the fraud intel or payments risk group.
  • In addition to reaching out directly to the FBI, file a complaint through its Internet Crime Complaint CenterOff-site link.
  • If your financial institution is part of a regional payments association, report the mule to the association as many of these associations send out money mule and fraud alerts to their members.
  • Finally, report the suspected money mule recruitment website to the Federal Trade CommissionOff-site link by filing a complaint either through its online system or by calling 877-FTC-HELP (877-382-4357).

Earlier this year, my colleague Dave Lott blogged about efforts by law enforcement officials to crack down on money mules. As the example I'm describing here shows, the effort to bring down mules must be collaborative. As part of this collaborative effort, banks and other financial institutions have a critical role to play in identifying mule accounts and sharing this information with law enforcement as well as with each other. To those like the banker who reached out to me and other financial institutions that identify money mules, don't remain silent. In the immortal words of Ray Parker Jr., "If there's something weird, and it don't look good, who you gonna call?" Make the call to law enforcement and others to bring these mules and hopefully the larger criminal organizations behind them down.