SAR - Money Mule

Posted By: CSB98

SAR - Money Mule - 08/24/20 07:17 PM

We have a couple of customers that we believe got involved in a scam that they really didn't know anything about. They received benefit payments from the State of AZ and then received an SBA EIDL loan deposit about a week later. Most, if not all, of the money went out of the accounts before we realized what was going on. In these instances, would you list the customer as a suspect in the SAR? I truly don't believe these individuals knew what they were doing. I think there is a common denominator somewhere (e.g. a website they visited or something they clicked on Facebook), but haven't been able to figure it out.
Posted By: BrianC

Re: SAR - Money Mule - 08/24/20 07:38 PM

The FinCEN Advisory on Imposter and Money Mule Scams should be you guide for unemployment benefit fraud. Money Mules can be "unwitting" but they are still assisting in laundering funds. I would list them as subjects.
Posted By: edAudit

Re: SAR - Money Mule - 08/24/20 09:17 PM

The term is subjects and not suspects as per FinCen. I hope that this terminology is helpful.
Posted By: ColoradoAML

Re: SAR - Money Mule - 08/24/20 10:12 PM

It sounds to me from the description that these customers were victims of an account takeover. If a crook initiated unauthorized transactions through their account without their knowledge, I wouldn't list them as a subject and I'd explain why in the narrative. I'm first to label unwitting money mules as subjects, but I believe they have to take some action to participate to be a MM (other than open the wrong attachment or whatever they may have done).
Posted By: BrianC

Re: SAR - Money Mule - 08/24/20 10:40 PM

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Most, if not all, of the money went out of the accounts before we realized what was going on.

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I truly don't believe these individuals knew what they were doing.


That's a good point Colorado. Did the customer initiate transfers out of the account and/or withdraw cash to take to MoneyGram to wire out or did the scammers compromise the ID & Password and take the money out of the account through unauthorized transfers? The answer to that question would affect whether the customer is a subject or not.

The way I interpreted the above statement is that the customer received the fraudulent payments and then assisted in moving the laundered funds under the guise of a romance scam, international payment processor, etc.
Posted By: CSB98

Re: SAR - Money Mule - 08/25/20 01:15 PM

One of the customers withdrew the money at the local Walmart using his debit card and via Cash App. The other individual withdrew the funds in cash and then sent the money off using some other method. It doesn't as though it was an account takeover . . . seems like the customer was involved but didn't realize it was a scam.
Posted By: ColoradoAML

Re: SAR - Money Mule - 08/26/20 02:29 PM

In that case I would consider them a money mule and list them as a subject as Brian suggested.

They facilitated the transfer of stolen government funds to a criminal. If your understanding is that they didn't know what they were doing, I'd provide the customer's explanation of why they did it, where they think the money came from, what they were instructed to do, how they came in contact with the person that gave them instructions, if they personally profited in any way that you can see or if the entire amount was sent, and any other information you think is pertinent.

Law enforcement will determine what to do with them, if anything. My understanding from the FBI is that first time, unwitting money mules are not a target, but repeat offenders aren't necessarily given the same leeway. We've had many relatively new customers launder money as mules through all sorts of romance scams, work from home scams, etc., and later learned that they repeatedly conducted similar activity at other institutions.