Crossword Genius

Noisy criminal? (7)

Ross

I believe the answer is:

rustler

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'criminal?' is the definition.
(rustler is a kind of criminal)

I don't understand the remainder of the clue.

Can you help me to learn more?

(Other definitions for rustler that I've seen before include "One who takes livestock" , "one whose stock-taking is dishonest" , "Horse thief" , "Stock taker?" , "lawbreaker" .)

I've seen this clue in The Mirror.
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