If you hold or are applying for a UK e-money or payment institution licence, the FCA money mule review published in September 2026 is the clearest signal yet of where supervisors will look next: the first six months of a customer relationship. E-money institutions recorded the steepest rise in mule offboarding of any firm type, and most of those accounts were closed soon after they were opened. That points squarely at onboarding and early transaction monitoring, which are also the controls an authorisation case officer tests hardest.
For founders, the practical reading is simple. A financial crime framework that looks fine on paper but catches mules only after months of activity is now a known weakness in the sector, and the FCA has the data to prove it.
What the FCA found
The FCA surveyed 35 regulated firms and ran a working group with 22 firms that examined 140 cases across 7 fraud types. Its headline figures, all from the September 2026 review:
- Firms closed 238,396 suspected money mule accounts in 2025, up from 184,935 in 2023 and 233,269 in 2024. Growth slowed in the final year.
- E-money institutions recorded the largest year-on-year increase, with offboarding volumes up 164.6% on 2024.
- 74.1% of EMI offboarded accounts and 56.9% of payment institution offboarded accounts were closed within 6 months of opening.
- Payment institutions and EMIs made 215 and 105 filings respectively to the National Fraud Database in 2025, compared with none reported in 2023.
The review also traced how money leaves the system. Cash-out activity was concentrated between the second and fifth mule account in a chain, with the highest concentration at the second. International and crypto cash-out methods were typically higher in value.
What does the FCA money mule review mean for EMI licences?
Three things, in our view.
First, early-life monitoring is now a supervisory theme. If most of your mule closures happen inside six months, your onboarding risk scoring and first-transaction rules are where a supervisor will start. Applicants should expect questions on both in the authorisation process, and existing licence holders should expect them in any follow-up contact.
Second, intelligence sharing is no longer optional in practice. The jump in National Fraud Database filings by payments firms shows the sector moving from zero participation to routine use in two years. The FCA explicitly points firms to the information-sharing provisions in the Economic Crime and Corporate Transparency Act 2023. A firm that cannot show it uses them will stand out.
Third, crypto on-ramps sit inside the risk picture. Because crypto cash-outs tend to be higher in value, EMIs serving crypto businesses, and crypto firms using EMI rails, should map that flow explicitly in their risk assessment.
What the FCA asks firms to do
The review asks firms to use the findings to inform their own assessment of mule risk, review and strengthen their detection and disruption controls, understand how criminals move funds between accounts, respond to emerging cash-out patterns, and use data and intelligence appropriately. Alongside the National Economic Crime Centre, the FCA is alerting firms to the findings.
How this fits the wider licensing picture
The UK remains one of the most demanding places to hold an EMI licence, and this review adds to the evidence base supervisors will use. If you are choosing between the UK and an EU route, compare how each regime treats financial crime expectations on our UK e-money licensing page and the e-money jurisdiction comparison. For crypto firms weighing an EMI partner, the UK crypto licensing page sets out the parallel regime, and our quarterly licensing reports track supervisory themes over time.
Sources
- FCA: Money mules activity and cashing out, multi-firm review findings (September 2026)
- FCA press release on money mule findings (September 2026)
This article is for information only and is not legal advice.