I have been looking for weeks for a policy on privatley owned ATM's. We have businesses that service their own and some that have nothing to do with the ATM except collect a monthly fee for having it in their store. I'm not sure how to address the two. What documentation do I need to get from the non service ATM store (contracts, etc.)and how do I do monitoring when the account is not at our bank. Any help would be appreciated.

For businesses that have privately owned ATMs (they service with cash) I rate them as a high risk and monitor/review their cash activity. I also have a privately owned ATM section on my BSA risk assessment.

For those that just collect a monthly fee I would just notate thier account. I can't imagine that fee they take in would be very high regardless if it is a flat rate or a per usage fee. I don't think you need to pull contracts and monitor the account because there is probably nothing to monitor on your end.

Hope that helps...

Private ATM owners, similar to MSBs, may be a higher risk business but that is only one factor to consider in establishing the risk rating. For example, if you have banked a customer for several years, have conducted several reviews that have revealed no concerns with the source of cash for replenishment, nature of business activities, ownership, etc., then you should be able to reduce the risk rating based on your review and findings.