The Financial Crimes Enforcement Network today issued a statement reminding banks of how to apply a risk-based approach to conducting customer due diligence on independent ATM owners or operators pursuant to the 2016 customer due diligence rule. The advisory noted that the level of money laundering and terrorism financing risk varies with these customers and that they do not automatically present a higher level of risk.
FinCEN recommended several pieces of information that banks could collect to assess the risk posed by independent ATM owners and operators. This could include details on: organizational structure and management; operating policies, procedures and internal controls; currency servicing arrangements; source of funds if a bank account is not used to replenish the ATM; locations where the independent owner or operator is organized and maintains places of business; expected and actual ATM activity levels; and whether ATM operations are ancillary to other retail operations or are the primary business of the customer.
