MuleHunter: The Software Shield India Needs Against Cyber-Fraud-KBS Sidhu IAS(Retd)

KBS Sidhu, IAS (retd.), served as Special Chief Secretary to the Government of Punjab. He is the Editor-in-Chief of The KBS Chronicle, a daily newsletter offering independent commentary on governance, public policy and strategic affairs.

The Home Minister’s call to all banks to adopt “mule hunter” software is more than a technical directive; it is a statement that cyber-fraud has become an infrastructure problem requiring national-scale tools, regulatory discipline and citizen education (short video). An effective response must, therefore, marry India’s new MuleHunter system with global best practices on money-mule controls and a serious investment in investor and account-holder awareness.

What exactly is MuleHunter?
On Tuesday in New Delhi, Union Home Minister Amit Shah, addressing the National Conference on Tackling Cyber-Enabled Frauds & Dismantling the Ecosystem, organised by the CBI, called on all banks to adopt the “Mule Account Hunter” software as a common shield against digital financial crime. This came alongside a stark data point: India has frozen thousands of crores out of a much larger pool lost to cybercriminals, with millions of SIMs and devices blocked and tens of thousands of arrests linked to cybercrime in just the last few years. The core message was that the country’s digital financial architecture can no longer be secured by piecemeal efforts; it needs shared tools that can see across institutions.

The technical heart of that push is MuleHunter.AI, an AI/ML-powered model developed by the Reserve Bank Innovation Hub after studying behavioural patterns typical of mule accounts across multiple banks. Instead of relying on crude rule-books, the system ingests transaction flows, account histories and related data to score accounts on their likelihood of being mules, allowing banks to focus scarce investigative capacity on the most suspicious nodes. In Shah’s framing, this “Mule Account Hunter” is a joint initiative of the central government and RBI, intended as a common utility for all banks to identify and purge fraudulent accounts used to launder stolen money.

Early pilots with large public sector banks have reportedly shown materially better detection accuracy and far fewer false positives than legacy systems, which often flooded compliance teams with noise while real mules slipped through. On the policy side, Shah has already claimed that lakhs of mule accounts have been unearthed and suspicious transactions running into thousands of crores prevented through co-ordinated efforts that include such tools and the Indian Cyber Crime Co-ordination Centre (I4C). His New Delhi remarks, coupled with a deadline to onboard all financial entities—including co-operative banks—into the broader cyber-crime co-ordination network, effectively seek to make MuleHunter part of India’s basic financial plumbing.

What other countries do – and what India must copy
India is not alone in grappling with money-mule infrastructure; regulators elsewhere have already moved to treat it as a systemic risk rather than an isolated crime pattern. The UK’s Financial Conduct Authority, for instance, has published detailed findings on banks’ controls against mule activity and now expects proportionate, risk-based systems that combine enhanced onboarding, sharper transaction monitoring and active data-sharing with law-enforcement. Firms are judged not just on whether they have a policy, but on whether they can actually detect common mule behaviours and intervene quickly.

In parallel, the UK government has launched a dedicated Money Mule Action Plan, backed by a national economic crime strategy, that couples public awareness, bank-level analytics and social-media platform responsibility to disrupt mule recruitment at source. The National Economic Crime Centre works with banks and police, not just to freeze individual accounts, but to dismantle mule networks, while promising targeted campaigns on child and youth exploitation through “easy money” offers. It is noteworthy that the UK’s “biggest ever crackdown on money mules” is framed as a whole-of-system operation, not merely an upgrade to banking software.

At the multilateral level, the Financial Action Task Force has highlighted cyber-enabled fraud and mule accounts as critical channels for illicit financial flows, urging countries to hard-wire mule detection into their anti-money-laundering regimes and to strengthen cross-border information-sharing. The emerging global template is straightforward: advanced analytics at the institutional level, shared intelligence at the system level, and sustained public education to reduce the supply of unwitting or desperate mules. Seen against this backdrop, India’s MuleHunter initiative is a necessary catch-up move, not a futuristic indulgence.

To match international practice, the government will have to move beyond exhortation and build a clear regulatory spine: timelines for integration across all regulated entities, minimum performance standards for mule-detection systems, safeguards for wrongly flagged customers, and structured channels for information-sharing between banks, telecoms and enforcement agencies. Otherwise, MuleHunter risks becoming yet another well-branded project that never quite escapes pilot mode.

Where the citizen stands – and why investor education is the missing leg
Even the most sophisticated AI will fail if citizens continue to act as raw material for fraud factories—both as victims and as money mules. Shah’s New Delhi speech indirectly acknowledged this by highlighting the sheer scale of India’s digital explosion: hundreds of billions of UPI transactions annually, a billion internet users and tens of crores of basic bank accounts, turning cyber-security from a matter of economic safety into a pillar of national security. The challenge is that the same infrastructure which powers inclusion also powers exploitation.

On the victim side, most digital-fraud stories still begin with a familiar script: a phishing message, a fake customer-care call, a remote-access app, a too-good-to-be-true investment, or a fraudster masquerading as a loan app or UPI support. On the mule side, international experience shows that many recruits are ordinary citizens—students, gig workers, indebted households—who agree to “let their account be used” for a commission, without fully understanding that they are becoming part of an organised criminal enterprise.

Regulators abroad have explicitly asked banks to treat customer communication on money-muling as a core obligation, not a CSR afterthought—warning clients that allowing their accounts to be used, even once, can bring criminal liability, credit blacklisting and account closure. In the UK action plan, the government talks of public awareness material, school-level engagement and an online hub with guidance and support on money-muling. India has investor-education programmes, but few that speak bluntly to these cyber-risks in the language people actually use.

A serious investor-education and account-holder-education strategy around cyber-fraud and mule accounts would need four elements.

Plain-language mass messaging: Every digital channel—UPI apps, SMS alerts, bank statements, ATM screens—should repeat a few non-negotiable rules: never share OTPs or PINs; never install remote-access apps at the behest of “support” agents; never click on “KYC update” links outside official apps; and never, under any circumstance, let others route money through your account for a fee.

Targeted campaigns for vulnerable groups: Students and young adults need to see money-mule warnings in colleges, on job portals and social-media platforms where “easy money” offers flourish. Senior citizens and first-time digital users require in-person sessions in branches and panchayat spaces, using regional languages and real local case-studies.

Integration into formal curricula and investor programmes: NCERT textbooks, university courses, SEBI-RBI investor education modules and CSC-led digital literacy programmes must all treat cyber-fraud and money-muling as core content, not optional add-ons. Treating “digital prudence” as a life-skill is as important as teaching compound interest.

Clear, efficient redressal pathways: People will only take warnings seriously if the system proves it can actually help them when things go wrong. That means widely publicising the 1930 helpline, making app-based reporting seamless, and using tools like MuleHunter to freeze suspect flows quickly enough that victims see their money saved or recovered in real time.

For ordinary investors, one more message is crucial: fraud risk is now part of financial risk. A person who runs a well-diversified mutual fund portfolio but casually shares OTPs or responds to a fake “sextortion” email is not a conservative investor—they are taking a massive, unpriced risk in a different dimension. Investor education, as we currently design it, speaks volumes about asset allocation but whispers about cyber-hygiene; that balance needs to be reversed.

The real test of MuleHunter
MuleHunter, if implemented well, could be to cyber-fraud what UPI was to payments: an invisible, shared rail that quietly makes the system smarter and more resilient. But just as UPI’s success depended on relentless ecosystem-building—standardisation, open APIs, incentives for banks, and user-friendly apps—the success of MuleHunter will depend on whether it becomes a ubiquitous, well-governed utility rather than a headline-driven pilot.

That will require uncomfortable choices: insisting that even politically connected co-operative banks plug in or face sanctions; publishing anonymised metrics on detection accuracy and wrongful flagging; and creating appeal mechanisms for customers who are frozen out by over-zealous algorithms. And it will require acknowledging that no AI, however sophisticated, can substitute for a citizen who has been taught to pause, doubt and verify before tapping “pay”.

In New Delhi this week, Amit Shah has put his political weight behind the software piece. The question is whether regulators, banks and market educators will do the slower, less glamorous work of fixing the services and the users—so that MuleHunter does not become just another clever acronym in India’s long battle against financial fraud, but a genuinely shared shield for ordinary depositors and investors.

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