Typology group
Funnel, mule and third-party deposits
Accounts used by other people: many depositors into one account, mules sweeping small credits out, and entities that exist only to hold an account.
The typologies
5| Typology and a scenario that places there | Channels | BSA |
|---|---|---|
| Funnel accountsFunnel account: multiple depositors, out-of-area cash | CSH CHK | BSA BSA-AML-15 |
| Third-party depositsThird-party cash deposits into business accounts by non-signers | CSH CHK RDC | BSA BSA-AML-15 · BSA BSA-CDD-3 |
| Money mulesMule pattern: many small inbound transfers swept out the same day | ACH RTP P2P | BSA BSA-AML-15 |
| Many-to-one and one-to-manyMany-to-one: 15+ originators paying one beneficiary within 7 days | ACH WDM RTP P2P REM | BSA BSA-AML-15 |
| Shell and front companiesShell company accounts with no payroll or operating expenses | WDM WIN | BSA BSA-AML-15 · BSA BSA-AML-07 |