238,000 Money Mule Accounts Closed: Why Following the Payment Trail Matters in Fraud Cases

The Financial Conduct Authority has revealed the scale at which suspected money mule accounts are being identified across the UK financial system, highlighting the role these accounts can play in moving the proceeds of fraud and other financial crime.

According to findings published by the FCA on 23 September 2026 and updated on 24 September, financial firms closed 238,396 suspected money mule accounts during 2025.

That compares with 233,269 in 2024 and 184,935 in 2023.

The FCA's findings also highlight how criminal funds may be moved through multiple accounts before eventually being withdrawn, transferred overseas or converted into other forms.

For victims of fraud, businesses and their legal advisers, the figures demonstrate why identifying the account that first received a payment may be only the beginning of understanding where the money ultimately went.

What Is a Money Mule?

A money mule is an individual whose account is used to receive or transfer money connected to criminal activity.

Some people knowingly allow their accounts to be used. Others may be recruited through misleading job advertisements, social media approaches, online relationships or offers of easy money without fully understanding where the funds have come from.

Once money reaches a mule account, it may quickly be transferred again.

Funds can potentially pass through several accounts, businesses, payment services, cryptocurrency wallets or jurisdictions before being withdrawn or spent.

This movement can make what initially appears to be a straightforward fraud considerably more difficult to unravel.

Fraud Proceeds Can Move Through Multiple Accounts

The FCA's latest work looked not only at the identification of suspected mule accounts but also at how criminal proceeds move through the financial system.

It found examples of organised groups transferring funds through multiple bank accounts before cashing them out.

That distinction is important.

The account that initially receives money from a fraud victim does not necessarily belong to the person who organised the underlying fraud.

Instead, the payment trail may involve:

• An initial recipient account.
• Transfers to additional accounts.
• Payments to associated individuals or companies.
• Cash withdrawals.
• Cryptocurrency transactions.
• International payments.
• Purchases of goods or other assets.

Understanding those connections can therefore require examination of the wider financial and corporate picture rather than focusing solely on the first recipient.

Why Following the Payment Trail Matters

When an individual or business discovers that money has been transferred as a result of suspected fraud, attention understandably focuses on the receiving account.

Establishing what happened after that payment can be equally important.

A financial investigation may seek to construct a chronology showing when payments were made, which individuals or companies appear connected to them and where available evidence indicates the money was subsequently directed.

Conflict International's Fraud and Financial Investigation Services support individuals, businesses, law firms and professional advisers where suspected fraud involves diverted payments, investment schemes, false invoices, cryptocurrency transactions or connected individuals and companies.

Depending on the circumstances and the information lawfully available, enquiries may examine:

• Payment information supplied by the client.
• Recipient details.
• Companies associated with relevant individuals.
• Directors and shareholders.
• Corporate addresses.
• Websites and digital identities.
• Cryptocurrency wallets and transaction identifiers.
• Litigation and insolvency information.
• Connections between individuals and businesses.
• Activity spanning different jurisdictions.

The purpose is not to assume that everybody appearing within a payment chain has participated in fraud.

Instead, information should be assessed carefully so that established facts can be distinguished from associations, indicators and matters requiring further investigation or disclosure.

When Fraud Investigation Leads to Asset Tracing

Establishing how a fraud occurred and tracing assets are closely related, but they are not the same thing.

A fraud investigation generally focuses on understanding the suspected misconduct, identifying relevant parties and examining how payments, communications or records were handled.

Asset tracing has a different objective: identifying property, corporate interests, cryptocurrency or other financial interests potentially connected to a subject.

Where a substantial financial loss has occurred, the two areas may overlap.

Our earlier guide, What an Asset Trace Can Really Reveal, explains how asset tracing brings together property, corporate, legal, financial and open-source information to build a wider intelligence picture.

An asset trace may identify assets held directly by a subject, but it can also reveal companies, associates, addresses, transactions or ownership connections that warrant further examination.

Importantly, identifying an apparent asset does not itself freeze, seize or recover it.

Those steps generally require action by solicitors, courts, financial institutions or relevant authorities.

Acting Quickly Following Suspected Fraud

Speed can matter after suspected fraud because money may be moved rapidly between accounts and jurisdictions.

Anyone who believes they have transferred money as a result of fraud should normally contact their bank or payment provider promptly and report the incident through the appropriate official channels.

Available evidence should also be preserved.

Useful records may include:

• Bank statements and payment confirmations.
• Emails and messages.
• Telephone numbers.
• Website addresses.
• Contracts and invoices.
• Company details.
• Cryptocurrency wallet addresses.
• Transaction identifiers.
• Screenshots of platforms or online accounts.
• Details of any further demands for payment.

Information that appears insignificant at the outset can later help establish a chronology or identify links between people, businesses and transactions.

More Account Closures Do Not Necessarily Mean More Fraud

The FCA's figures should also be interpreted carefully.

Although the number of suspected money mule accounts closed by firms has increased considerably since 2023, that does not necessarily mean mule activity itself has grown at the same rate.

The FCA says the increase may also reflect growth in firms' customer bases and improvements in their ability to detect and take action against suspicious accounts.

Nevertheless, almost 240,000 suspected accounts being closed in a single year demonstrates the scale at which banks and regulators are dealing with the movement of potentially illicit funds.

It also highlights why a fraud investigation may need to look beyond the initial recipient when attempting to understand what happened to stolen or misdirected money.

Investigating Complex Financial Fraud

Fraud involving multiple recipients, companies, digital assets or international payments can become difficult to understand from transaction records alone.

A structured investigation can help establish a chronology, identify relevant individuals and organisations, examine corporate and financial connections and separate verified information from assumptions.

Conflict International supports individuals, businesses, solicitors and professional advisers dealing with complex fraud and financial matters in the UK and internationally.

Where suspected fraud involves significant financial loss, multiple payment recipients or potentially concealed assets, contact Conflict International in confidence to discuss the information available and the enquiries that may be proportionate.