From what little I know about Privately Owned ATM Monitoring, I believe it's the Bank's job to monitor for possible money laundering. And to do this we review the account statement showing the credits from the ATM vs. the checks cashed to replenish the ATM. There are some months that these numbers aren't as close ($18,000 in credits vs. $10,000 in checks cashed). How much of a difference is enough to dig deeper? We are a very small community bank located in a very rural area. This customer is at least 20 minutes from us and I would be willing to bet they replenish the ATM with funds from their cash register at times. It would only make sense instead of them driving all the way to the bank to deposit the cash and then cashing a check to take the cash back to the store. What responsibility do I have as the BSA Officer? This is our first and one and only privately owned ATM.

As part of our due diligence and monitoring, we request a copy of any reports or logs regarding ATM activity. The bank has a right to ask for it. Many of them are also our MSB customers so we work that into our site visit. We request quarterly after we get them started.

Another thing to consider is if they are 20 minutes away they may get more or less depending on how often they come into the bank. Also think about the Customer's fluctuation in traffic with regards to activity. Events and holidays can def make a difference also. We are a small bank also with 11 locations. Some rural and some metro. The most rural seem to have the most activity. Hope this helps some.

It would also depend on the customer and his business. If he only owns 1 or more private ATMs then the cash withdrawals should agree to the ATM usage, and this should be mandatory. However, if the ATM is in his business, store, deli, etc, then he could use part of his normal business proceeds to replenish the ATM. This makes our job more difficult and you need to consider the ATM usage and determine if it is reasonable that part or all of the cash to replenish the ATM can come from the business proceeds as opposed to cash withdrawals. The optimum would be for you to require cash withdrawals that agree with the ATM usage and then the cusotmer would deposit cash from his business proceeds as is usually the case.