FCA money mule review puts EMI onboarding under the microscope
The FCA's September 2026 review shows e-money institutions recorded the steepest rise in suspected money mule account closures — up 164.6% year on year — with three quarters of those accounts shut within six months of opening.
The Financial Conduct Authority's latest review of money mule activity, published in September 2026, surveyed 35 regulated firms and examined 140 cases across seven fraud types. Firms closed 238,396 suspected money mule accounts in 2025, up from 184,935 in 2023.
E-money institutions recorded the largest year-on-year increase in offboarding, with volumes up 164.6% on 2024. The timing data is the sharpest signal: 74.1% of EMI-offboarded accounts and 56.9% of payment institution accounts were closed within six months of opening — pointing squarely at onboarding and early transaction monitoring as the controls supervisors will test hardest.
The review also traced how money leaves the system. Cash-out activity was concentrated between the second and fifth mule account in a chain, and international and crypto cash-out methods were typically higher in value. Payment institutions and EMIs made 215 and 105 filings respectively to the National Fraud Database in 2025, compared with none reported in 2023.
The FCA notes that rising offboarding can reflect better detection rather than weaker controls, particularly at fast-growing digital-first firms. But the practical reading for the sector is clear: a financial crime framework that catches mules only after months of activity is now a known weakness, and the FCA has the data to prove it.
If your business banks with a UK EMI or fintech, expect onboarding and early-account monitoring to get stricter, not looser. Legitimate businesses should be ready to evidence source of funds and expected transaction patterns up front — and anyone applying for an EMI or payment institution licence should assume the authorisation case officer will probe exactly these controls.