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#1978679 - 11/24/14 07:37 PM Verbal Contract with ISO for Privately Owned ATMs
THSCPA Offline
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Joined: Sep 2004
Posts: 113
New York
We have run into a couple customers that allow ISO's to place ATMs in their facilities (restaurants, etc). They claim that they only have a verbal agreement with the ISO. I am curious what others are doing in this type of situration?

I contacted the ISO and they say there is no legal requirement to have a written agreement.

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BSA/AML/CIP/OFAC Forum
#1979242 - 11/26/14 12:35 PM Re: Verbal Contract with ISO for Privately Owned ATMs THSCPA
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
It is likely true that it is not legally required; however, from a BSA/AML perspective that would raise the risk level of your customer. It would be prudent for you to document your due diligence on the ISO to ensure they are reputable, especially if the credits will be flowing through your institution.
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#1979243 - 11/26/14 12:52 PM Re: Verbal Contract with ISO for Privately Owned ATMs THSCPA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
Does the OP mean they just put an ATM on site and they pay the restaurant a monthly fee or some similar payment and the restaurant has nothing to do with the actual ATM operation????
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