other accounts in a layered chain. By the time the originating bank or law enforcement traces the funds back, the money has typically moved on. Account opening can move faster at smaller banks than at large institutions, and fraud networks have noticed. Inbound activity runs against a smaller volume base at smaller institutions, which cuts both ways for detection. Much fraud detection technology was built around outbound patterns. Federal authorities have been documenting the pattern. FinCEN issued an advisory in August 2025 describing how recruited money mules open accounts across multiple institutions to receive and move illicit proceeds. The agency issued additional guidance in September 2025 covering similar schemes targeting individual victims, where mules typically take a percentage fee for moving funds. The Department of Justice’s annual Money Mule Initiative has acted against thousands of mules in each recent cycle. A few operational priorities deserve attention. Account-opening reviews should weigh indicators federal authorities have flagged, including inconsistent occupation information, addresses that match those of other recently opened accounts and documentation that suggests third-party preparation. Transaction monitoring should give inbound activity the same level of scrutiny as outbound activity. Incoming wires that are quickly followed by transfers to cryptocurrency exchanges or money services businesses are the clearest indicator of a mule account in use. Community banks should consider building or expanding an active 314(b) practice, one of the strongest tools available, as information sharing lets institutions coordinate directly when suspicious patterns appear. Filings should name the suspected mule, describe the inbound and outbound pattern and reference the relevant typology source so law enforcement has what it needs to act. Community banks that embed inbound detection into their fraud posture make it harder for these schemes to run. The attention to individual accounts that defines community banking is exactly what this work requires. Scott Anchin (scott.anchin@icba.org) is senior vice president of strategic initiatives and policy for ICBA. The Department of Justice’s annual Money Mule Initiative has acted against thousands of mules in each recent cycle. 22318 Midland Drive • Shawnee, KS 66226 • NMLS #194708 YEARS 26 Local Partners, Shared Values, Stronger Communities We’re not a national giant – we’re your local wholesale lending partner. Together, we bring your customers the best of both worlds: • Fannie Mae Seller/Servicer • Government programs – FHA, VA, and USDA-GRH • Local expertise – We live and work in your community • Trusted partnership – Backed by 26 years of service • More options – Flexible lending without losing the personal touch Andrew Holtgraves Senior Vice President 913-558-2555 andrew@mischomeloans.com PARTNER WITH US 17 In Touch
RkJQdWJsaXNoZXIy MTg3NDExNQ==