Money mules: how “easy money” can cost you your freedom

Participation in “money mule” schemes is not side work — it’s a criminal offense

Every year, the number of crimes involving so-called “money mules” continues to rise. The scheme is simple: fraudsters recruit individuals willing to provide their bank cards, accounts, or e-wallets “to help with transfers” or “to work with clients.”

In reality, these accounts are used to move funds obtained through criminal means — and the person who agrees to “just transfer the money” effectively becomes an accomplice to a crime.

Ukrainian courts are increasingly issuing convictions for participation in such schemes, with penalties ranging from fines to long-term imprisonment.

What criminal liability applies

1. Fraud (Article 190 of the Criminal Code of Ukraine)

If a “money mule” assists others in unlawfully obtaining someone else’s funds, it qualifies as fraud. Penalties range from fines to up to 12 years of imprisonment. Even if a person does not deceive anyone directly, the offense could not occur without their involvement.

2. Illegal actions with payment instruments (Article 200 of the Criminal Code of Ukraine)

Any manipulation with bank cards or electronic money — such as using another person’s card or engaging in informal cryptocurrency transactions — constitutes a criminal offense. The law provides for substantial fines or restrictions of liberty.

3. Acquisition or sale of property obtained through a crime (Article 198 of the Criminal Code of Ukraine)

Unlawfully acquiring, receiving, storing, or selling property obtained through criminal means — even without prior agreement — is punishable by up to 3 years of imprisonment.

For instance, purchasing a “new” smartphone at a suspiciously low price without documents may result in criminal liability if it is later proven that the phone was stolen — and you knew or should have known it.

If you promised in advance to buy, hide, or resell such property, the situation becomes far more serious: you are considered an accomplice to the main crime (such as theft, fraud, or illegal trade), and the punishment may be as severe as for the principal offender.

4. Legalization (laundering) of criminal proceeds (Article 209 of the Criminal Code of Ukraine)

Transferring or converting illicit funds to disguise their criminal origin qualifies as money laundering. The punishment is up to 12 years of imprisonment and possible confiscation of property.

To establish guilt, prosecutors must prove the unlawful origin of the assets and the individual’s awareness of their participation in the scheme.

5. Complicity (Article 27 of the Criminal Code of Ukraine)

A “money mule” may be deemed an accomplice if they facilitate the crime — by transferring funds, providing access, or otherwise enabling the illegal activity.

In such cases, the penalty may be equivalent to that imposed on the main perpetrator, with the degree of involvement considered at sentencing.

“I didn’t know”: how law enforcement and courts assess this defense

Under Ukrainian law, criminal liability arises only in the presence of guilt (Articles 23–25 of the Criminal Code), and the burden of proof lies with the prosecutor.
However, investigators and courts evaluate the individual’s awareness based on behavioral indicators, such as:

• multiple P2P transfers from unknown persons;

• immediate cash withdrawals after deposits;

• absence of legitimate reasons for large transactions;

• communication with “employers” only via messengers;

• unusually high pay for simple or unclear tasks.

These signs form a behavioral profile indicating that the person should have foreseen the criminal nature of their actions.
As a result, the claim “I didn’t know” is often met with skepticism. Still, if a person cooperates with law enforcement and helps identify organizers, they may be treated as a witness rather than a suspect.