BSA Consulting Trends: Student Mules

If you are involved with BSA/AML compliance, you know that it will keep you on your toes!  Bad guys are always looking for new ways to get around the rules! 

One newer development that is increasing dramatically is young people acting as “money mules”.  Fraudsters/money launderers will often target college students as they are finishing college and potentially heading abroad.  They get students to sell their bank account details, such as their login information, for as little as $100-$200.  The fraudsters then take over these accounts and use them to launder money.  Gaining access to an established account helps the fraudster avoid customer identification and customer due diligence procedures, which would come into play if they tried to open a new account.  Sometimes, the fraudsters will even convince the students to cooperate with them.  For example, the fraudster may deposit or wire a sum of money into the account and have the student transfer all but $200 to another account.  The student gets to keep the $200 for their trouble.  You can see where this might be an attractive money maker for a poor college student!

So, what should you do?

You need to be aware of your student accounts and what is considered “normal” activity for them.  How do you know what’s “normal”?  You refer to the customer due diligence questions you asked them at account opening.  You did do that, right?!  Sudden changes in transaction volumes, compared to what was normal, could indicate trouble.  Increased education for your student customers about the effects of fraud is another approach you could take to combat this.

BSA Consulting – Other Trends

Unfortunately, student mules aren’t the only new trend in BSA/AML compliance.  There are also noted increases in debit/credit card data breaches and fueling scams at gas stations.  Check out the March edition of our Banking on BCC Magazine for more.

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Published
2019/03/13
Deb Irving

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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