 Inside an Irish Money Laundering Operation: A Case Study
When Gardaí raided a remote farm in County Clare, they didn’t just uncover livestock and machinery—they unearthed a sophisticated money laundering scheme that had quietly converted criminal proceeds into assets that looked, on the surface, perfectly legitimate. This case illustrates a classic Irish money laundering typology, showing how criminals place, layer, and integrate illicit cash within Ireland’s financial and property systems. Placement: Converting Cash into Tangible Assets The operation began with large volumes of cash generated from drug trafficking and organised crime. Instead of depositing the money directly into banks, where suspicious transaction reports (STRs) might be triggered, the criminals purchased agricultural land, machinery, and livestock. By acquiring a functioning farm, they could explain away large cash movements as agricultural income. This is a common Irish adaptation: cash-rich illicit groups investing in rural property or cash-intensive businesses (such as pubs, car washes, or construction firms) to disguise their income sources. Layering: Complex Transfers and False Trails Once the farm was operational, transactions became deliberately complex. Animals were bought and sold across county lines, often with inflated or understated valuations. Equipment was leased through third parties, and funds were moved across multiple Irish bank accounts in amounts just under the €10,000 reporting threshold. The criminals also relied on “money mules”—individuals, often vulnerable or indebted, who allowed their accounts to be used for funneling funds. This layering process created a tangled financial trail, frustrating investigators trying to trace the money back to its illicit origins. Integration: Dirty Money Becomes ‘Clean’ Over time, the scheme succeeded in integrating illicit funds into the mainstream economy. The farm produced legitimate revenue streams: cattle sales, EU agricultural subsidies, and lease agreements. Criminal proceeds were effectively rebranded as farm income. The perpetrators then used these seemingly legitimate profits to invest in vehicles, luxury goods, and even overseas property. By this stage, the money appeared clean—making it extremely difficult to prove its criminal origin without extensive investigation. This case demonstrates several AML red flags relevant to Ireland:
The case was eventually cracked by the Garda National Economic Crime Bureau (GNECB), working in partnership with the Criminal Assets Bureau (CAB). Assets—including the farm, machinery, and livestock—were seized under proceeds of crime legislation. Under the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010, amended in line with EU directives, individuals convicted of laundering can face up to 14 years in prison and unlimited fines. In addition, the Central Bank of Ireland can levy significant administrative sanctions against financial institutions that fail to detect and report suspicious activity. This farm case typifies money laundering typologies in Ireland: criminal cash embedded in rural businesses, layered through complex transactions, and integrated into the economy via legitimate-looking revenue. For compliance officers, solicitors, accountants, and financial institutions, it serves as a reminder that criminal proceeds don’t always appear as stacks of cash in city banks—they may be hiding in plain sight on a quiet farm road in the Irish countryside. Source: https://www.irishmirror.ie/news/irish-news/crime/gallery/inside-clare-farm-criminal-assets-35794821
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 Two Guest Contributors wrote a piece on this story. See the other one here. Nail bar worker charged with money laundering after €80k seizure [August 26, 2025] Summary: i. Defendant: Quang Nguyen, 28, of Swords, Dublin; works in a nail bar. ii. Seizure: Gardaí recovered about €78,500 and £10,800 at his home. iii. Charge: Money laundering under section 7 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 — accused of possessing those amounts as proceeds of crime. iv. Explanation given: Nguyen told Gardaí that the euros came from friends to help him open a nail bar in Drogheda; he could not explain the origin of the British currency. The people allegedly supplying the funds have not yet been contacted or verified by Gardaí. v. Background & other facts:
What’s interesting: i. Large cash holdings + unexplained source(s): The combination of a high cash amount and inability to clearly verify or document the origin of funds (especially from “friends”) is a classic red flag. Being able to trace and validate origins of large cash deposits is critical for AML compliance. ii. Cross-currency risk / multiple currencies: The presence of both euros and British pounds, with only partial justification for one, adds complexity. Monitoring for unexplained foreign currency inflows is important, especially in jurisdictions close to or dealing with different currencies. iii. Use of funds for business investment claims vs. money laundering allegations: Claiming the money was intended for investment (e.g. starting a nail bar) is a common defense. Compliance must ensure that business investment claims are backed by legitimate documentation (invoices, contracts, etc.) and corroborated sources, not just anecdotal “friend-gave-me-money.” iv. Presumption of innocence but burden of proof on source verification: The case highlights that while legal process presumes innocence, from an institutional/compliance standpoint you must act on strong indicators. Documenting KYC, performing enhanced due diligence where needed, and maintaining records so you can support or contest claims about fund origin are vital. Source: https://www.waterford-news.ie/nail-bar-worker-charged-with-money-laundering-after-80k-seizure_arid-68834.html
 The saga of Thierry Fialek‑Birles—known in some circles as “Terry Birles,” the self‑styled Irish aristocrat—reveals the elaborate mechanics by which confidence fraud and money laundering intertwine, particularly in cross‑border contexts. His multi‑million‑euro scheme, which ensnared celebrated French comedian and filmmaker Dany Boon, was woven with layers of deception that offer vivid insight into typologies of transnational financial crime.
Claiming decency, heritage, and legal expertise, Fialek‑Birles convinced Boon he descended from an ancient Irish aristocratic family and was an Oxford‑educated maritime lawyer. Boon was drawn in by references to glitzy affiliations, including the Royal Cork Yacht Club, and grand plans involving yacht restorations and tax‑free investments with the (fake) Irish Central Bank These personal details were the foundation of trust—crafted authenticity intended to mask the reality of fraud and exploitation. Over several months, Boon transferred approximately €2.2 million for maintenance of his yacht and a further €4.5 million into a supposedly tax‑free investment scheme. Of course, that scheme was entirely fictitious. What emerges is a clear typology: criminals often deploy a mirage of legitimacy—be it elite education, exotic family history, or exclusive clubs—to lower suspicion and facilitate large financial transfers. Once the money was in, Fialek‑Birles dissolved the façade, vanishing from view. Subsequent investigations revealed he had exploited a network of shell companies across jurisdictions—Irish‑registered entities including South Seas Merchants Mariners Ltd Partnership (SSMM), as well as entities in Samoa, the British Virgin Islands, Antigua and Barbuda, and beyond. This corporate scaffolding served two purposes: obscuring the true ownership of funds and imprinting complexity into the trail—hallmarks of layering in money laundering typologies. Irish courts responded with stringent measures, including freezing orders (Mareva injunctions) that restrained assets—including yachts in Cork, property in Youghal, and offshore accounts—totalling upwards of €4.87 million in damages awarded to Boon by a High Court judgment. This demonstrates the integration of civil and criminal strategies to protect victims and recover assets. What does this typology teach us? First, exploitation of social engineering and reputation—as in claims of aristocracy or legal expertise—remains a potent tool in money laundering and fraud. Second, the use of front-companies and offshore jurisdictions is a recurring tactic to launder proceeds and obscure paper trails. Third, effective cross-border cooperation—from Interpol notices to freezing orders—is crucial for disruption. In essence, the fake aristocrat case underscores the risks when legitimacy becomes a façade. Criminals exploit cultural or institutional trust; legitimate structures—like courts and law enforcement—must respond with equal dexterity. Vigilance toward seemingly charismatic figures, investment opportunities, or inherited privilege remains a critical defense in the typology of transnational fraud and money laundering. Source: https://www.theguardian.com/world/2025/aug/26/dany-boon-french-film-star-the-fake-irish-aristocrat-thierry-fialek-birles-and-the-missing-euros  Two Guest Contributors wrote a piece on this story. See the other one here. In late August 2025, a Dublin District Court case drew renewed attention to the use of cash-intensive businesses as potential vehicles for money laundering. Gardaí seized more than €78,000 and £10,800 from the home of a nail bar worker who claimed the funds were pooled from friends to open a new salon in Drogheda. While the accused insisted the cash was legitimate, the identities of these “friends” were never verified. Charged under section 7 of Ireland’s Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, the case highlights the vulnerability of cash-based enterprises, such as nail bars, hairdressers, and takeaways, to exploitation by criminals seeking to disguise illicit proceeds.
Cash-intensive businesses (CIBs) are particularly attractive to launderers because their normal operations involve large volumes of physical currency, much of it untraceable. This environment creates opportunities to blend “dirty” money with legitimate earnings. A nail bar might take in hundreds of small cash payments daily, which makes it difficult for regulators or auditors to identify whether declared revenue figures accurately reflect real customer activity. By simply overstating takings, a business can introduce illicit cash into its books with little outward indication of wrongdoing. The laundering process often begins with placement: introducing the illegal funds into circulation. In the case of a CIB, this might mean recording criminal proceeds as part of the day’s takings. From there, layering can occur through deliberate manipulation of records or structured deposits designed to avoid triggering automatic reporting thresholds. In Ireland, banks are obliged to flag cash lodgements above €10,000, but launderers often “smurf” deposits, breaking down large sums into smaller amounts to slip under the radar. Once lodged, the money appears as legitimate business income, allowing it to be integrated into the financial system without immediate suspicion. This mechanism is not new, but it remains a persistent challenge for Irish authorities, particularly as criminal groups adapt quickly. The relatively low barriers to entry for businesses like nail bars or food outlets—combined with their dependence on cash—make them ideal for money launderers who seek plausible cover for unexplained wealth. Unless authorities can demonstrate a mismatch between declared turnover and actual activity, these businesses can provide a convincing front. Ireland’s anti-money laundering framework has attempted to respond to such risks. Under the 5th EU Anti-Money Laundering Directive, factors such as high reliance on cash or ownership by non-resident individuals are considered elevated risk indicators. Designated professionals, from accountants to property agents, are expected to carry out enhanced due diligence and file suspicious transaction reports where warranted. Yet the practical challenge remains: small-scale cash-based businesses operate at the margins of scrutiny, often falling below the thresholds that attract regulatory attention. The Dublin nail bar case underscores the importance of vigilance in this area. Cash-intensive businesses are part of everyday life and, in most instances, perfectly legitimate. However, their very nature provides the camouflage that money launderers need. For Ireland, strengthening oversight, improving the detection of red flags, and fostering a culture of questioning suspicious narratives will be essential if such businesses are to be prevented from becoming conduits for illicit finance. Source: https://www.breakingnews.ie/ireland/nail-bar-worker-charged-with-money-laundering-after-e80k-seizure-1795607.html 
What happened? Dutch online bank Bunq has been fined €2.6 million by the Dutch Central Bank (DNB) for failures in its anti-money laundering (AML) controls. The regulator cited serious shortcomings between January 2021 and May 2022, where Bunq failed to properly investigate and report potential financial crime indicators. [NB Bunq passports its credit institutions services into Ireland from the The Netherlands pursuant to the terms of the EU Directive 2013/36/EU]. DNB noted that Bunq had previously been warned and fined for similar weaknesses, yet meaningful improvements were not made. Despite this, Bunq maintains that it takes its gatekeeping responsibilities seriously, pointing to its use of advanced technology and ongoing system improvements. This fine comes against a backdrop of heightened regulatory scrutiny in the Netherlands, where major lenders including ING, ABN Amro, and Rabobank have also faced significant enforcement actions and legal challenges over AML control deficiencies. banks must know who their customers are, where the customers’ money comes from and what customers intend to do with financial products, e.g. payment accounts. - De Nederlandsche Bank 25 August 2025 What is important for MLROs to note from this case This case underlines the importance of sustained, demonstrable improvements in AML frameworks, particularly following regulatory warnings or fines. For an MLRO, the key lesson is that technology alone is insufficient without robust governance, oversight, and a culture of accountability. Regulators expect not only initial remediation but also evidence of lasting effectiveness in transaction monitoring, customer due diligence, and suspicious activity reporting. An experienced MLRO should recognize that repeated regulatory findings indicate weaknesses in escalation, board engagement, and risk ownership. Embedding AML into the bank’s strategic priorities—through continuous training, effective quality assurance, and proactive engagement with regulators—is essential. Failure to do so not only risks financial penalties but also reputational damage and possible criminal liability for the institution and senior management. Work conducted by the DNB DNB conducted an examination into the way in which Bunq complies with the Wwft. As part of the examination, DNB assessed how Bunq analyses and assesses its risks of facilitating money laundering and terrorist financing. In addition, it examined customer files and the transaction monitoring alerts associated with these files and conducted interviews with relevant officers. The high-risk files examined showed that Bunq was deficient in following up on its transaction monitoring alerts. As a result, signals of possible financial crime were not investigated in sufficient depth, if at all. Bunq was also unable to demonstrate why transactions with similar characteristics were reported to FIU-NL in one case and not in the other. As a result, there was a risk that unusual transactions were not detected, or not detected in time and that they were not reported, or not reported in time. Transaction monitoring deficiencies can cause illicit money flows to continue unchecked. Bunq failed to exercise adequate ongoing monitoring in the four files on which DNB's administrative fine is based. As a result, Bunq did not have sufficient insight into these customers and their transactions. Given the severity and extent of the deficiencies in these files, DNB considers the fine imposed both necessary and appropriate. What is the justification for the size of the fine? Between 2018 and 2023, DNB carried out several examinations into Bunq’s compliance with the Wwft. During these examinations various instances of non-compliance with the Wwft were identified, that were found to be both severe and culpable. DNB already took enforcement action on several occasions, including imposing a fine. However, this has not resulted in sustained compliance with the Wwft by Bunq. Following DNB’s examinations, Bunq has not made sufficient progress in complying with its statutory obligations under the Wwft. DNB has therefore decided to impose a punitive fine on Bunq due to the severity of the non-compliance with Section 3(2)(d) of the Wwft. DNB’s enforcement approach is primarily aimed at compliance with the law. In addition, the more severe and culpable the non-compliance, the sooner DNB will impose a fine. This is done on a case-by-case basis. Bunq's size and ability to pay have been taken into account, and the fact that Bunq completed a remedial programme to address the identified deficiencies after DNB's most recent examination has been taken into account in favour of the bank. Can Bunq appeal? Bunq lodged an objection to DNB's decision to impose a fine. The objection process is still pending. A decision becomes final if no legal remedy has been exercised against it. Any interested party may lodge an objection against the decision within six weeks of its date. The decision on the objection can be appealed in court within six weeks. Further appeal against the court ruling may be lodged with the Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven – CBb). If no objection, appeal or further appeal is lodged, the decision becomes irrevocable. The table shows the current status of this decision. What is the gatekeeper role of the DNB? From the DNB's website: "Tackling money laundering is a priority for the government because it is key to effectively fighting all manner of serious crime. Concealing the origin of criminal proceeds enables perpetrators to steer clear of the investigative authorities and enjoy their ill-gotten gains undisturbed. The Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en terrorismefinanciering – Wwft) aims to ensure that our financial system is not abused for money laundering and terrorist financing. Under this legislation, banks act as gatekeepers and are obliged to carry out anti-money laundering controls. This means that banks must know who their customers are, where the customers’ money comes from and what customers intend to do with financial products, e.g. payment accounts. Once customers are accepted, the bank must monitor them on an ongoing basis and report unusual transactions to the Financial Intelligence Unit (FIU-NL) so that the investigative authorities can examine suspicious transactions. Banks may use a risk-based approach to monitor their customers, meaning that high-risk customers will require more in-depth monitoring than low-risk customers." Sources:
Overall fraud offences have increased by 73% in the first six months of this year compared to the same period in 2024, according to provisional crime statistics from An Garda Síochána. The garda figures are subject to change, with official statistics published by the Central Statistics Office on a quarterly basis. The statistics show significant increases across most forms of fraud, with the biggest rise recorded in forgery or false instruments, which rose by 200% between January to the end of June 2025 compared to the same time last year. An Garda Síochána said "deception or other" rose by 178%, shopping or online auction fraud was up 166% and money laundering increased by 82%. Reports of "bogus tradesmen" had a 57% increase during this time compared to previous statistics for this period, while fraud relating to accommodation rose by 22% and so-called "account takeover fraud" rose by 18%.  However, gardaí said other forms of fraud decreased, including a drop of 88% in reports of counterfeit notes and coins. Instances of phishing, vishing and smishing reduced by 26% - such crimes are usually carried out online, via a phone call or text message. Insurance fraud also dropped by 45%, the figures showed. Information and statistics on other crimes are also reported. See source link below. Source: https://www.rte.ie/news/crime/2025/0818/1528888-garda-provisional-crime-figures/
Det Insp Cryan said this case highlights the role of professionals who help oil the wheels of criminality, known in the policing world as “professional enablers”. The Garda National Economic Crime Bureau (GNECB) is running several probes into suspected property frauds, Detective Inspector Michael Cryan told the Sunday Independent. This type of fraud came to prominence in June when a solicitor and a former millionaire were jailed for using fake deeds to register new owners of two Dublin houses. Det Insp Cryan said lawyers, accountants, investment advisers and company formation advisers, who are complicit through negligence or dishonesty, are increasingly being targeted in crime investigations. “The GNECB continues to target the professionals and professional enablers who commit so called white-collar crime for their own benefit or the benefit of others,” he said. “These can be solicitors, accountants and/or trusted local businesspeople. This is important as their actions erode public trust in the legal and business world. Property re-registration fraud can only work with the involvement of solicitors who use their trusted legal positions to help commit these frauds. “We have other investigations ongoing into property fraud as well,” added Det Insp Cryan, who said this type of fraud is a “relatively new” one, first surfacing in the last decade.  In June, Herbert Kilcline (63), a former solicitor, of Bessborough Parade, Rathmines, Dublin, and Philip Marley (53), of Ashtown, Dublin, were convicted in connection with using false deeds to change the registered ownership of the properties without the owners’ knowledge. Det Insp Cryan said this case highlights the role of professionals who help oil the wheels of criminality, known in the policing world as “professional enablers”. “A solicitor’s signature carries a lot of weight,” he said. One of those properties, Dublin Circuit Criminal Court heard, was rented in Phibsborough, with a lease income of €245,000 transferred to the US by Marley and never recovered. The other was a boarded-up Victorian house on St Mary’s Road in Dublin that had been repossessed by a financial institution. The fraud came to light when the St Mary’s Road property appeared on the Property Price Register in 2018 as sold to a company for €525,000, and the sale was challenged. The house has since been sold legitimately for €1.6m. Marley, helped by Kilcline, used false deeds to register two companies as the owners of the two properties. Kilcline, who is no longer a practising solicitor, was jailed for two-and-a-half years, and Marley was jailed for three years. While Marley was identified by the sentencing judge as the “orchestrator” of the fraud, Kilcline played a key role. Without Kilcline’s professional lawyer’s signature passing off fake conveyancing deeds as genuine, the scheme would not have worked, according to Det Insp Cryan. “That property registration fraud would not have worked without a solicitor’s involvement in it,” he said. Kilcline is not the only professional who has crossed the line between advising clients and actively helping them to break the law for criminal gain, but he is one of the few to be prosecuted for doing so. Cases that have been investigated by the GNECB include a solicitor who was probed for his continued representation of various members of a family notorious for making bogus insurance claims. He has not been prosecuted. And most solicitors who have received prison sentences in recent years were found to have stolen from client funds or from institutions, for personal gain. Michael Lynn (57) was jailed last year for five-and-a-half years for a €27m mortgage fraud which he used to fund his property investments. Fellow former solicitor Thomas Byrne (59) was convicted in 2013 of stealing €52m from six banks and defrauding 13 clients of their houses or money. Kilcline was in a different category as a classic “professional enabler” who rubbed shoulders with criminals, personally and professionally. The solicitor first came to Det Insp Cryan’s attention when he was leading the investigation into the murder of teenager Marioara Rostas. Just 18 years old, Ms Rostas was begging with her brother on Lombard Street in Dublin city centre when she went missing. Her body was later found in the Dublin mountains. Gangland criminal Alan Wilson was a suspect. Kilcline knew Wilson’s associates and was one of several people arrested in connection with possessing or withholding information. Kilcline later claimed to the Sunday World that he convinced one of Wilson’s associates to testify against him, and bring gardaí to the site where Marioara was buried. Despite Fergus O’Hanlon’s testimony, Wilson was acquitted by a jury in 2014. Kilcline later claimed that, as a result, his life was in danger from Wilson. Marley was among Kilcline’s more respectable clients. From north Dublin, he was flamboyant and, at one time, a wealthy businessman. He ran a male striptease act called Celtic Knights in the 1990s, before making €10m aged 33 from his student accommodation business, Ely Property Group. He was romantically involved with reality TV star Dana Wilkey, of The Real Housewives of Beverly Hills. His property group was liquidated in 2013, and he went bankrupt, owing €6.6m, in 2019. In the intervening years, Marley teamed up with Kilcline. Marley was promoting a US company that planned on taking over abandoned and derelict properties in Ireland, doing them up, and asserting squatters’ rights to claim ownership after 12 years. Kilcline was his legal adviser. Marley and Kilcline went from that to property registration fraud, which they engaged in between 2016 and 2018. At one point, Marley wrote to the Property Registration Authority, under a false name, pretending to be an employee of Kilcline. Sentencing Marley, the judge called him the “author” of the scheme that was motivated by personal gain. Professionals had been “duped” and ended up being investigated as a result of his actions, Judge Sinéad Ní Chúlacháin said. But she rejected Kilcline’s argument that he was guilty of “professional negligence” rather than criminality. It seemed Kilcline’s troubles came all at once. As he was being probed for the property fraud, he was convicted of social welfare fraud, falsely claiming disability and other payments worth €127,000. He was sentenced to 21 months in jail. Kilcline, who was impacted by thalidomide – the morning-sickness drug that caused birth defects in thousands of babies born worldwide in the 1950s and 1960s – blamed the fraud on his difficulty in accessing compensation. Kilcline’s lawyers told the court that he had been a “covert human intelligence source” for gardaí, his life had been threatened, and gardaí uncovered “two separate conspiracies to murder him”. A spokesperson for Tailte Éireann, a state agency responsible for property registrations, said it cannot comment on any active investigation. “We actively assist An Garda Síochána with any requests received. Tailte Éireann has a dedicated counter-fraud unit that seeks ways to combat property fraud,” the statement said. “One such initiative is Property Alert. This is a free service that provides an early notification, by email and/or text message, of certain activity on a property that you are monitoring. This allows you to take prompt action if you believe the activity is unexpected.” Source: https://www.independent.ie/irish-news/crime/gardai-home-in-on-lawyers-and-accountants-involved-in-suspected-property-fraud/a505807651.html
We have a category for "Money Mules" on the right. Given the prevalence of money mule cases in Ireland, thought this piece from the UK FCA might be of interest. Fintechs and digital banks are particularly exposed to the risk of money mules, the research found. RUSI said banking-as-a-service (BaaS) companies that provide payment or lending services to other fintechs were particularly exposed — receiving 10 per cent of payments it tracked from money mule accounts. Hard stats:
Andrea Bowe, a director at the FCA overseeing its work on fraud and financial crime, said the watchdog was working with financial firms, law enforcement and international counterparts. The regulator is also eager for tech companies to do more, given recruitment of mules often happens on social media, she said. “We recognise the scale of the challenge in tackling fraud generally, which is why fighting financial crime is one of the pillars of the new strategy announced this year by the FCA,” she said. Research released on Thursday by the Royal United Services Institute, a security think-tank, has found money mules are playing a “significant role” in enabling fraud to become “a national security threat, undermining the rule of law and threatening the financial sector”. The RUSI research, based on data from Lloyds Banking Group, urged financial services companies to share more real-time data to tackle the problem, particularly as more than half of funds received by money mules is paid out within an hour. Fintechs and digital banks are particularly exposed to the risk of money mules, the research found. RUSI said banking-as-a-service (BaaS) companies that provide payment or lending services to other fintechs were particularly exposed — receiving 10 per cent of payments it tracked from money mule accounts. “New entrants to the market, such as BaaS providers, also appear to be being exploited by fraudsters,” RUSI said. “This calls for a robust regulatory response.” The Lloyds data showed that 57 per cent of the funds flowing through money mule accounts exited via the UK’s Faster Payment system to other accounts and 20 per cent by value went to a single digital finance firm, which was unidentified. About 10 per cent of the funds were withdrawn from money mule accounts in cash via ATMs or branches, RUSI said, while nearly a fifth went on debit card payments, including some to international money transfer companies. A much smaller amount, less than 1 per cent, went to cryptocurrency exchanges. “While it has been known about for many years, there are signs that the number of money mules is growing,” said Kathryn Westmore, senior research fellow at RUSI. “It is generally like a game of whack-a-mole, where you tackle it in one area and it pops up in another.” However, despite rising concern about the issue, there has been a sharp fall in the number of money mules being reported to the UK national fraud database, which can result in the person being blocked from opening another bank account for six years.
Industry experts say the sharp drop in money mule reporting reflects calls by the authorities for financial firms to treat vulnerable customers better instead of any reduction in fraud or in the targeting of young people to launder funds. “The key driver here is very large regulated entities responding to changing guidance from a regulator — that is borne out in the significant drop in filings relating to younger people,” said Simon Miller, director of policy, strategy and communications at Cifas. The government said last year it would work with banks and local authorities to ensure “vulnerable or exploited people” were not removed from the banking system. The FCA this year urged firms to improve how they treat customers in vulnerable circumstances. Miller said the drop in filings could also partly reflect a change in Cifas reporting rules to avoid banks filing cases where they only suspect someone of being a money mule rather than having evidence they were complicit — but this was thought to have only had a marginal effect. He added that more money mules were being trained by their recruiters in what to tell banks when they are questioned, which may have contributed to the lower number of filings. More people are handing over their identities to allow fraudsters to open separate accounts in their name. Ben Donaldson, managing director for economic crime at trade body UK Finance, said many money mules were tricked or coerced into it without knowing it is a crime for which they could be imprisoned, even though few are convicted. “I don’t think we can say all mules are victims but certainly many mules are victims, so it’s a complicated problem,” he said. Source: https://www.ft.com/content/6f517e05-0561-442f-842f-72eba8d125f3
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