Step 1: Hide— Marinate to conceal smell
Goal: Create a camouflage between you and the dirty money while the dirty money must become someone else’ s paper trail. You do not want to appear anywhere near the first transaction taking victims’ funds.
In any great dish, preparation starts before the first sauté. Here, the launderer conceals undesirable smells by letting it bathe in unwitting mules’ bank accounts. Mules are the soup of the day for today’ s internet fraudsters— the unwitting individuals who are tricked into allowing dirty money to be deposited in their personal bank accounts. Think of mules as aroma enhancing vessels— gig workers or the financially desperate pulled into schemes under the illusion of legitimate work.
Locating these mules is done through phishing schemes designed to hook with a click. For instance:
“ Work-at-home job! Just process payments.”“ Be a local representative for our global company— no start-up costs!”“ Receive money into your account and keep a commission— quick and legal!”
Chef’ s note:
Do not over marinate with too many deposits going into one mule account. Use only the freshest mules. If they have been used before, law enforcement( LE) may already know the aroma.
Step 2: Transfer— To add new textures / layers
Goal: Transfer the money to further distance it from the crime. Every transfer adds another layer that makes following the money more difficult.
Adding layers to lasagna or desserts is a culinary trick to introduce new textures and flavors and make dishes with subpar ingredients tasty. Layers add complexity and make tracing the original source ingredients difficult.
Direct your mules to move the funds into shell entities with innocuous registrations then spread the dirty funds repeatedly. Applications such as PayPal, Venmo and CashApp add efficiency to this stage of the meal prep. Money is moved from account to account, creating layer upon layer.
ACAMS Today | September – November 2025 15