Good Afternoon. I am reviewing my bank's private ATM owners. I have come across business that is receiving ATM settlements in the account at my bank but are not withdrawing any cash. They told the banker that they are withdrawing the cash at their main account which is at another bank. Does anyone have guidance on what to do with this? Can I make the business start withdrawing cash with my bank? Or move their ATM business to their other account? The BSA Exam Manual did not have much regarding this type of situation.
Thank you
If you're getting pushback from doing the right thing from Retail, look at these:
Ascertaining the sources of currency for the ATMs by reviewing copies of armored car contracts, lending arrangements, or any other documentation, as appropriate. (FFIEC BSA/AML Examination Manual, p. 249)
Admittedly, this is far more broad than what the examiners expect, particularly the phrase "any other documentation".
Appendix F lists the following as a red flag:
Sources of currency for the ATM cannot be identified or confirmed through withdrawals from account, armored car contracts, lending arrangements, or other appropriate documentation. (FFIEC BSA/AML Examination Manual - F-6).
The above more definitively suggests that there should be a process in place to identify or confirm currency sources - with the options of withdrawals, etc. The only problem is the continued vague inclusion of "appropriate documentation". This is where it comes down to risk appetite.
Personally, the first Bank I started doing AML had the ACH in -cash out requirement down pat back in 2007. The next one I worked at starting in 2008 had gotten a major comment back in 2007 for not tracking ATM cash. Lastly, I've heard from a lot of BSA/AML colleagues that they've gotten comments from examiners that expect the ACH in - cash out control. Some exceptions can be made - but the one you've mentioned doesn't seem worth making.