USA’s Financial Crimes Enforcement Network (FinCEN) has issued a statement to clarify how banks should conduct customer due diligence (CDD) on independent ATM owners or operators in a risk-based manner.
Owners/operators of all independent ATMs require bank accounts to get cash to be placed in the ATMs and to process all ATM transactions. FinCEN’s requirements for independent ATM owners/operators are consistent with its existing CDD and other Bank Secrecy Act (BSA)/AML requirements for any bank account. Banks must perform customer identification, verify beneficial ownership of legal entity customers, and engage in reporting currency transactions and suspicious activity. Additionally, banks must conduct CDD in a risk-based manner to generate risk profiles for all customers, including independent ATM owners/operators. FinCEN has emphasized that banks do not need to conduct additional due diligence just for independent ATM owners/operators.
Overall, independent ATM owners/operators do not inherently pose a greater ML/TF risk. This risk can vary depending on customer-specific circumstances, such as ATM location, transaction volume and the source of ATM cash funds. FinCEN’s statement will be beneficial for those independent ATM owners/operators who have faced challenges in getting and maintaining access to banking services.
Source: FinCEN, USA
