We have now entered into the Privately Owned ATM(POATM) world.
Upon a recent review of some of our businesses we have found a few have since placed an ATM in some of their businesses.

I was hoping someone had a example of what they added to their BSA Risk Assessement for POATM's.

After reviewing the FFIEC POATM guidelines I've created my POATM checklist to determine the initial risk and my monitoring tracking but the only thing left was the need to add this to the BSA Risk Assessment. In preparations for an upcoming exam was hoping to get this approved and in place.

IMO you need to differentiate between private ATMs that a business owner has in his business with multiple ATMs placed at different locations by a person or company. Everything being equal, the former would be lower risk than the latter. For the former, you should have a copy of the agreement that they have with their ISO and monitor the daily usage and cash withdrawal activity in the account. If cash withdrawals are less than the ATM usage you would need to determine if it is reasonable that the cash taken in by the business for their regular business activity would be sufficient to replenish the ATM. For the latter, we require a list of the business names and addresse where the ATMs are located, copies of agreements with each, site visits by bank staff and we also require cash withdrawals to match the usage in each ATM.

Devsfan- I appreciate your respone. I have everything in place that is stated within the BSA exam manual. I've collected the various ATM company agreements with our business owners but was wanting to see an example of how they added this to their BSA risk Assessment.

In the risk assessment, treat privately owned ATMs as one of the products or services offered by your institution. Acknowledge the risks involved then discuss the risk mitigants your institution has in place and the level of residual risk you perceive.

I am struggling with this as well. Like most things BSA, there is a lot of verbiage, not enough "how to." I have identified several POATM customers and am trying to develop a "Check list" or questionnaire to send to each, listing the required documentation.

Would you mind sharing what you have?

Look in the tools section of BOL, I shared one a while ago.

And it's a nice gift at that!

As navigation on this web site can be difficult if the sky is cloudy and you are new (welcome), click the blue tab that says "Banker Tools" at the top of this page. From the list of topics offered, check AML/BSA. On the page that looks like someone spilled the Scrabble box, click "Edit," then "find," and type in "ATM."

It's unlikely that anyone could effectively design a questionnaire for completion by the customer. I suggest you develop one for your employee to complete and your customer to sign.