BSA/AML/CFT: Money Mule Schemes
A money mule is a person who transfers illegally acquired money on behalf of or at the direction of another. The use of money mules helps criminals obscure the source, movement and destination of illicit proceeds. In some cases, a money mule is a willing participant facilitating the criminal activity. Many times; however, the money mule has no idea what they are doing. Money mules are often targeted and recruited which can come in many different forms such as online jobs scams, romance scams, social media, etc. Money mule networks are generally broken down into three types, unwitting, witting and complicit, each with their own transactional and behavioral indicators.
Kevin discussed money mules during our May AML/CFT Membership Group meeting. Hear what he had to say:
Published 2026/06/26
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).