Federal Deposit Insurance Corporation
550 17th Street NW, Washington, D.C. 20429-9990 Division of Supervision and Consumer Protection
SA-185-2009
October 29, 2009
SPECIAL ALERT
TO: CHIEF EXECUTIVE OFFICER (also of interest to BSA Compliance and
Security Officer)
SUBJECT: Fraudulent Work-at-Home Funds Transfer Agent Schemes
Summary: Individuals are using deposit accounts to receive unauthorized electronic funds
transfers and forward funds overseas to criminals.
The Federal Deposit Insurance Corporation (FDIC) is warning financial institutions of an
increase in schemes to recruit individuals to receive and transmit unauthorized electronic funds
transfers (EFTs) from deposit accounts to individuals overseas. These funds transfer agents,
often referred to as “money mules,” are typically solicited on the Internet by criminals who have
gained unauthorized access to the online deposit account of a business or consumer. In a typical
scenario, the criminal will originate unauthorized EFTs from a victim’s account to a money
mule’s deposit account. The money mule is then instructed to quickly withdraw the funds and
wire them overseas after deducting a “commission” (commonly eight to ten percent).
Criminals target online deposit accounts at institutions where business customers can originate
EFTs, such as automated clearing house (ACH) and wire transfers, over the Internet. Money
mules, however, can be customers at any depository institution where EFTs can be received and
funds withdrawn. In some cases, the money mule may be an unknowing accomplice in a fraud
scheme. Because EFTs are often made immediately available by the receiving institution, funds
may be removed and wire transferred overseas before the fraud is detected. Refer to SA-147-
2009 http://www.fdic.gov/news/news/specialalert/2009/sa09147.html for more information on
fraudulent EFT schemes.
Money mule schemes can take many different forms, but most involve receiving unauthorized
EFTs into a deposit account and then withdrawing the funds or forwarding them on to another
party via another EFT. The following are common scenarios:
• Online job posting Web sites are used by criminals to locate individuals seeking
employment with flexible work hours that can be performed from home. These work-athome
schemes often involve written employment contracts, job descriptions and
procedures to legitimize the scam.
• Advance fee scams promising large monetary rewards for acting as a financial
intermediary can entice individuals to participate in this activity.
• Mystery shopping jobs may be used that require the employee to assess the performance
of money service businesses by completing EFTs and then evaluating the service using
customer satisfaction forms.
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• Social networking sites may be used to recruit individuals to act as money mules.
Criminals conjure up various imaginative stories to befriend and persuade individuals to
receive and forward stolen funds.
• Some hesitant or skeptical money mules have been intimidated, harassed and threatened
by their criminal “employers” to process the funds transfers quickly and with secrecy.
• The personal identifiable information provided by the money mule might later be used to
commit identity theft or account takeover.
The following are examples of events that may indicate money mule account activity:
• A deposit account opened with a minimal deposit soon followed by large EFT deposits.
• Deposit customers who suddenly begin receiving and sending EFTs related to new
employment, investments, business opportunities or acquaintances (especially
opportunities found on the Internet).
• A newly opened deposit account with an unusual amount of activity, such as account
inquiries, or a large dollar amount or high number of incoming EFTs.
• An account that receives incoming EFTs then shortly afterward originates outgoing wire
transfers or cash withdrawals approximately eight to ten percent less than the incoming
EFTs.
• A foreign exchange student with a J-1 Visa and fraudulent passport opening a student
account with a high volume of incoming/outgoing EFT activity.
Money mule activity is essentially electronic money laundering addressed by the Bank Secrecy
Act and Anti-Money Laundering Regulations. Strong customer identification, customer due
diligence, and high-risk account monitoring procedures are essential for detecting suspicious
activity, including money mule accounts. Financial institutions can find additional guidance
about customer identification, account monitoring, suspicious activity reporting, and identity
theft red flags below:
FDIC Risk Management Manual of Examination Policies - Bank Secrecy Act
www.ffiec.gov/bsa_aml_infobase/documents/FDIC_DOCs/BSA_Manual.pdf;
FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual
www.ffiec.gov/bsa_aml_infobase/default.htm and
FFIEC Identity Theft Red Flags – Interagency Final Regulations and Guidelines
www.fdic.gov/news/news/financial/2007/fil07100.pdf
Financial institutions should act promptly when they believe fraudulent or improper activities
have occurred, such as those of a money mule. Appropriate actions may include, but are not
limited to, filing a Suspicious Activity Report and/or closing the deposit account in accordance
with existing, board-approved account closure policies and procedures.
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Cyber-fraud incidents and other fraudulent activity may be forwarded to the FDIC’s Cyber-Fraud
and Financial Crimes Section, 550 17th Street, N.W., Room F-4004, Washington, D.C. 20429, or
transmitted electronically to alert@fdic.gov. Questions related to federal deposit insurance or
consumer issues should be submitted to the FDIC using an online form that can be accessed at
http://www2.fdic.gov/starsmail/index.asp.
For your reference, FDIC Special Alerts may be accessed from the FDIC’s website at
http://www.fdic.gov/news/news/specialalert/2009/index.html. To automatically receive FDIC
Special Alerts through e-mail, please visit www.fdic.gov/about/subscriptions/index.html.
Sandra L. Thompson
Director
Division of Supervision and Consumer Protection
Distribution: FDIC-Supervised Banks (Commercial and Savings)
Note: Paper copies of FDIC Special Alerts may be obtained through the FDIC's Public
Information Center, 1-877-275-3342 or 703-562-2200.