238,000 suspected money mule accounts: why account closures are not the win banks think

The FCA has published numbers that look, on first read, like progress. Firms closed 238,396 suspected money mule accounts in 2025, up from 233,269 in 2024 and 184,935 in 2023 (FCA). Behind that trajectory sits a less flattering finding: criminals are moving fraudulent funds through multiple accounts and typically cash out between the second and fifth, at which point tracing becomes materially harder (FCA). The regulator is signalling that closure volumes are not the metric that matters.

Key Executive Takeaways

• UK firms shut 238,396 suspected mule accounts in 2025, but criminals are cashing out by the fifth account, meaning higher closures do not equate to better disruption.
• The National Crime Agency estimates more than £100bn is laundered through the UK or UK corporate structures annually, and the FCA now expects firms to intervene earlier in the payment chain, not just close accounts after the fact.
• Boards should expect supervisory attention to shift from closure counts to intelligence sharing, cross-firm detection speed, and controls on repeat-offender accounts.

The metric problem

Closure counts have become the industry's default proof of effort. The FCA's data undermines that framing. The regulator explicitly notes that rising closures may reflect customer growth and better detection rather than a higher proportion of mule activity (FCA). More pointedly, some accounts had been used repeatedly for mule activity, and for fraud, before firms shut them down, which the FCA reads as evidence of established criminal infrastructure rather than isolated incidents (FCA). If accounts are recycling through the system, closure is a lagging indicator of failure, not a leading indicator of control.

Where the demographics point

The age breakdown reframes the customer-risk conversation. Closures were highest among customers aged 26 to 39 at 91,073, with the sharpest year-on-year jump among those aged 40 to 49, rising from 25,760 in 2024 to 37,274 in 2025 (FCA). The under-25 cohort remains large at 85,425. For retail banks, this challenges the assumption that mule risk concentrates in younger, digitally-recruited customers. Financial pressure on mid-career customers appears to be widening the recruitment pool, which has implications for onboarding thresholds, transaction monitoring calibration, and the communications firms send when unusual inbound payments hit an account.

The supervisory direction

Steve Smart, executive director of enforcement and market oversight at the FCA, said: 'It's good that financial firms are taking action on mules, but banks, law enforcement, technology companies and consumers all have a role to play in stopping people being drawn into criminal activity' (FCA). Read alongside the FCA's role in the nine system priorities coordinated with the NCA, Home Office and Treasury, the direction is clear: firms are one node in a wider intelligence architecture, and the regulator's action plan is being built around better ways for firms and law enforcement to share intelligence on suspected mule activity (FCA). That is a governance question, not a technology one.

What this means for the C-suite

Expect the next round of supervisory engagement to probe the speed at which suspicious activity is escalated between firms, not just within them. Boards that can only report closure volumes will look behind the curve. Those that can show reduced dwell time between first suspicious inbound and disruption, and evidence of cross-firm signal sharing, will be positioned for a supervisory conversation the FCA has clearly already started.