Money mule risk in business accounts: receiving and forwarding criminal funds can close a legitimate company bank account

A money mule receives or transfers criminal funds on behalf of someone else. Business accounts can be targeted because larger transfers and commercial-looking payments attract less attention than personal transfers. The FCA's September 2026 review found suspected mule activity in business, charity and other legal-entity accounts as well as personal accounts.

A mule account receives money and moves it onward

The FCA defines money mule activity as receiving or transferring criminal funds on behalf of others. Criminals can ask a person or business to accept a payment, keep a commission and forward the remainder to another account.

A legitimate bank account can become part of laundering even if the account holder did not commit the original fraud. Agreeing to move unexplained funds can create serious legal and banking consequences.

Commercial accounts can be attractive mule channels

The FCA's September 2026 multi-firm review found business-account offboarding for suspected muling and noted that criminal funds can move through chains of several accounts before being cashed out.

Fake trading relationships, investment deals, refund requests and work-from-home "payment agent" offers can all be used to justify pass-through transactions.

Investigate receipts that do not fit the business

A company that sells consulting services should question a large incoming payment from an unrelated consumer followed by instructions to forward most of it abroad.

Keep contracts, invoices and customer identity evidence proportionate to risk. Unexplained bank receipts should remain in suspense rather than being immediately forwarded on request.

Return mistaken money through safe banking channels

If someone claims to have paid the business by mistake, do not automatically send the same amount to a different account they provide. That pattern can be used to move fraud proceeds.

Contact the bank and, where appropriate, return to the verified original source using the bank's process.

Banks can restrict or close accounts they suspect are being misused

Financial institutions monitor mule activity and can freeze transactions, request evidence or terminate accounts according to legal and contractual obligations. The FCA reported 238,396 suspected mules were offboarded in 2025 across surveyed firms.

Respond to bank queries with clear commercial evidence rather than trying to route payments through another account to avoid review.

Use transaction context, not only payment amount

Monitor new counterparties, rapid in-and-out transfers, unusual international destinations and payments unrelated to normal products or suppliers.

Train staff handling refunds and treasury because mule activity can look like a customer service problem or urgent transfer rather than a classic phishing email.

Worked example: a small agency unexpectedly receives £75,000 from a personal account. A supposed new client asks the agency to keep £5,000 as a fee and send £70,000 to a foreign supplier it has never dealt with. The company should stop, preserve the communication and contact its bank rather than act as a transfer intermediary.

Use an inbound-payment exception report for receipts outside normal customer patterns. This is especially valuable for companies with bank details published publicly.

Do not assume only newly opened accounts are at risk. The FCA's 2026 findings show suspected mule activity can also involve older established accounts, so ongoing monitoring matters after onboarding.

Worked example: a genuine ecommerce company receives £120,000 from an unfamiliar corporate payer and is then told to forward £110,000 to three overseas accounts because the payer supposedly overfunded a purchase. That is not a normal refund pattern. Finance should stop the transfers and ask the bank to review the incoming funds.

Monitor velocity between incoming and outgoing payments. Criminal money often moves rapidly through several accounts, so same-day pass-through transactions unrelated to ordinary gross margin can be a useful alert.

Train sales teams not to accept deals where the company's main role is moving money rather than supplying real goods or services. A lucrative "commission" for processing funds can be a mule-recruitment tactic dressed as a commercial opportunity.

Keep bank queries centralised with compliance or finance leadership. Inconsistent explanations from several employees can increase concern and delay legitimate access to the account.

Escalate customers whose payments repeatedly arrive from unrelated third parties. There can be legitimate reasons, but a pattern of incoming money from many personal accounts followed by rapid refunds or onward transfers deserves AML and fraud review.

Use customer onboarding and transaction monitoring together. A plausible company name at onboarding does not explain later behaviour where funds arrive from unrelated consumers and leave immediately to new beneficiaries.