Navigating AML/BSA Requirements for Privately Owned ATMs

Privately owned ATMs have become a preferred choice for people who need quick cash, but their use can also increase the risk of money laundering and other financial crimes. As a result, the Financial Crimes Enforcement Network (FinCEN) has imposed certain regulations that are specific to privately owned ATMs. 

Financial institutions are required to be compliant with BSA rules and regulations. Such compliance needs to be well documented and consistent to ensure financial institutions are adequately identifying POATM customers and mitigating those risks. 

On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a Statement on Bank Secrecy Act Due Diligence for independent ATM owners and operators. The purpose of the statement is to “provide clarity to banks on how to apply a risk-based approach to conducting customer due diligence (CDD) on independent Automated Teller Machine (ATM) owners or operators, consistent with the requirements set out in FinCEN’s 2016 CDD Rule.” Financial institutions’ BSA POATM program must be included in the bank’s policies and procedures, comprehensive risk assessments, and monitoring programs. 

Attending this webinar will help you stay ahead of the curve and ensure that your business is fully compliant with AML/BSA requirements. Learn all about the specific regulations that apply to privately owned ATMs and safeguard your business against financial crimes.

Financial institutions have used a variety of approaches to manage privately owned ATMs over the years. One of the most significant challenges with privately owned ATMs is the lack of controls over how currency is placed in the ATM - or how the ATM is refilled.  Without effective controls, there is a risk that ATM currency will come from illegal activity, which is a prime example of how money laundering can occur.

This session focuses on understanding and mitigating the risks of POATMs, which are being recognized and acknowledged by regulators and examiners. In this webinar, we will go over the areas that regulators and examiners are most concerned about when it comes to POATMs. This webinar's focus areas are based on best industry practices and supervisory experience.

• Understand the AML/BSA requirements for privately owned ATMs.
• Recognize high-risk transactions and suspicious activity.
• Grasp the importance of customer identification and due diligence for privately owned ATMs.
• Implement monitoring procedures to detect anti-money laundering irregularities.

• Understanding the difference between a "financial institution" and a "money services business"
• Identifying high-risk transactions
• The importance of performing customer identification and due diligence
• Implementing BSA compliance practices on privately owned ATMs 
• Assessing policies and procedures regarding POATMs
• Determining the effectiveness and thoroughness of training programs
• Ensuring qualified employee oversight of daily BSA operations regarding POATMs
• Independent Testing
• Conducting ongoing monitoring and reporting suspicious activity

• Compliance Officer
• BSA Officer
• BSA Personnel
• AML/BSA Personnel 
• AML Analysts
• Opening Accounts Personnel
• Risk Mitigation personnel
• Regulatory Compliance Professionals
• Owners, Operators, and Managers of privately owned ATMs
• Anyone who is involved in the AML/BSA compliance process