Current · Source: Reserve Bank of India · RBI/2010-11/462 · issued FY 2010-11 · ~2 min read
Quick answerRBI warns NBFCs that criminals use 'money mules' to launder fraud proceeds via deposit accounts. NBFCs must strictly follow KYC/AML/CFT norms, periodically update customer data, and monitor transactions to prevent misuse.
The rule, in the simplest words
NBFCs (companies that lend money but are not banks) must check who their customers really are when they open deposit accounts (accounts where people keep money).
Criminals trick people called 'money mules' to receive stolen money and quickly send it to others; NBFCs must watch for accounts that get money and send it out fast.
NBFCs must update customer details (like address and phone number) from time to time, so fake or old info doesn't hide bad guys.
NBFCs must also make sure their own bank accounts are not used to wash dirty money.
How it plays out — a real example
A KYC & compliance officer in Mumbai notices a new deposit account that receives a large cheque and immediately transfers the funds to another person, keeping a small fee. Remembering the RBI alert, she flags the account for review, updates the customer's address (which was fake), and stops the misuse, protecting her NBFC from legal trouble.
What changed
RBI issued a specific alert about 'money mules'—individuals recruited to receive and transfer illicit funds via deposit accounts. It reminded NBFCs to adhere strictly to existing KYC/AML/CFT guidelines and to ensure their own bank accounts are not misused for money laundering.
What it means for you
NBFCs face increased regulatory scrutiny on deposit account operations. They must strengthen customer due diligence, especially for accounts that receive and quickly transfer funds. Failure to detect mule accounts could lead to legal action, account suspensions, and reputational damage.
What you must do
Strictly implement KYC/AML/CFT guidelines from the Master Circular dated July 1, 2010.
Periodically update customer identification data after account opening.
Monitor transactions for unusual patterns like rapid in-and-out movements.
Verify customer addresses and contact details to prevent fake or outdated records.
Ensure your own bank accounts are not used for money laundering activities.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML teams at NBFCs, Deposit account holders at NBFCs
❓ Common questions
What is a 'money mule' in the context of NBFCs?
A money mule is an individual with a deposit account who is recruited—often unknowingly—to receive cheques or wire transfers and then transfer those funds to others, keeping a commission. Criminals use mules to launder proceeds from phishing, identity theft, and other frauds.
What should NBFCs do to prevent money mule operations?
NBFCs must strictly follow KYC/AML/CFT guidelines, periodically update customer data, and monitor transactions. They should also verify customer addresses and contact details to avoid fake or outdated records.
What are the consequences for money mules if caught?
Money mules may have their deposit and loan accounts suspended, face financial loss, and could face legal action for being part of a fraud. Enforcement agencies often find their addresses and contact details fake or outdated.
📜 Read the original circular — full text as issued by RBI
RBI/2010-11/462
DNBS(PD)CC.No 215/03.10.42/2010-11
April 05 , 2011
All Non Banking Financial Companies /
Residuary Non Banking Companies
Dear Sir,
Operation of deposit account with NBFCs and money mules
With a view to preventing NBFCs from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities, Reserve Bank of India has issued guidelines on Know Your Customer (KYC) norms/Anti-Money Laundering (AML) standards/ Prevention of Money Laundering Act, 2002 that are consolidated in the Master Circular DNBS (PD) CC No 184/03.10.42 / 2010-11 dated July 01, 2010 .
2. It has been brought to our notice that “Money mules” can be used to launder the proceeds of fraud schemes ( e.g., phishing and identity theft) by criminals who gain illegal access to deposit accounts by recruiting third parties to act as “money mules.” In some cases these third parties may be innocent while in others they may be having complicity with the criminals.
3. In a money mule transaction, an individual with a deposit account in a bank/NBFC is recruited to receive cheque deposits or wire transfers and then transfer these funds to accounts held on behalf of another person or to other individuals, minus a certain commission payment. Money mules may be recruited by a variety of methods, including spam e-mails, advertisements on genuine recruitment web sites, social networking sites, instant messaging and advertisements in newspapers. When caught, these money mules often have their deposit and loan accounts suspended, causing inconvenience and potential financial loss, apart from facing likely legal action for being part of a fraud. Many a times the address and contact details of such mules are found to be fake or not up to date, making it difficult for enforcement agencies to locate the account holder.
4. The operations of such mule accounts can be minimized if NBFCs follow the guidelines contained in the Master Circular on Know Your Customer (KYC) norms /Anti-Money Laundering (AML) standards/ Combating of Financing of Terrorism (CFT)/Obligation of banks under PMLA, 2002. NBFCs are, therefore, advised to strictly adhere to the guidelines on KYC/AML/CFT issued from time to time and to those relating to periodical updation of customer identification data after the account is opened and also to monitoring of transactions in order to protect themselves and their customers from misuse by such fraudsters.
5. NBFCs are also advised to ensure that their accounts in banks are not used for the purpose of money laundering in the manner specified above.
Yours sincerely
(Uma Subramaniam)
Chief General Manager-in-Charge
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2010-11/462 · issued FY 2010-11. The plain-English explanation above is BankPulse’s own independent summary.
Periodically update customer identification data after account opening.
💻 IT / Systems
Monitor transactions for unusual patterns like rapid in-and-out movements.
📜 Compliance
Strictly implement KYC/AML/CFT guidelines from the Master Circular dated July 1, 2010.
Verify customer addresses and contact details to prevent fake or outdated records.
Ensure your own bank accounts are not used for money laundering activities.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML teams at NBFCs, Deposit account holders at NBFCs), your first concrete step on “NBFCs warned on money mule accounts” is: “Strictly implement KYC/AML/CFT guidelines from the Master Circular dated July 1, 2010.” (RBI issued this FY 2010-11).
Circular: RBI/2010-11/462 -- NBFCs warned on money mule accounts
Issued: FY 2010-11
Action required: Strictly implement KYC/AML/CFT guidelines from the Master Circular dated July 1, 2010.
Action required: Periodically update customer identification data after account opening.
Action required: Monitor transactions for unusual patterns like rapid in-and-out movements.
Action required: Verify customer addresses and contact details to prevent fake or outdated records.
Action required: Ensure your own bank accounts are not used for money laundering activities.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=6326&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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