FCA has published the findings from its views of the adequacy of PSP systems and controls against money mule activity. As now seems to be standard, it found that some firms are using innovative solutions such as facial recognition, device profiling and geolocation in a proportionate way, but others are not applying the same standards. FCA noted that some firms, when they identify a mule account, do not always report it promptly, which means there is a delay in other firms being notified. It also found that firms could do more to improve customer awareness of the risks of acting as a money mule.
As ever, where firms needed to improve had a direct impact on the likely adequacy of their systems and controls. In particular, if firms do not collect the right information at onboarding, they are unlikely to be able to identify behaviour later that should raise a red flag.