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#2154284 - 11/20/17 07:10 PM Privately Owned ATM Question
Megaman Offline
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Joined: Jul 2017
Posts: 131
Hi All,

I am new to Privately Owned ATMs. How does a bank monitor for tax evasion and money laundering when a business customer uses store proceeds to refill the ATM that he owns?

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#2154311 - 11/20/17 08:21 PM Re: Privately Owned ATM Question Megaman
thomasj Offline
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Joined: Mar 2001
Posts: 5,063
Pennsylvania
It is very difficult and many banks will require the customer to deposit all of their sales and withdraw the cash to replenish the machine - often from an account to be used solely for the ATM activity if the dispensed cash and cash withdrawals don't add up it is very easy to see this way.

My former institution did not do this, so what I had to do was to calculate the money given out by the machine (total of the ACH deposits from the ATM processing company over a specific time period) and add that amount to the customer's cash deposits to determine if the amount was reasonable. If the total that they are putting in the machine combined with the cash deposits is too high for that business, I would question what the source of cash was.
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#2154394 - 11/21/17 05:13 PM Re: Privately Owned ATM Question Megaman
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
We do what Thomas suggests. We currently have 41 PATMO's, the majority of which replenish them themselves, making them the highest risk. It's much easier to track when you require a stand alone account strictly for ATM activity. It's also helpful during our annual review when looking at a years worth of activity compared to previous year and what the ATM owner states is expected activity.

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#2156499 - 12/07/17 07:26 PM Re: Privately Owned ATM Question Megaman
Megaman Offline
100 Club
Joined: Jul 2017
Posts: 131
Hi All, I am in the process of reviewing my PATMOs and need to know what is required for the bank when the bank's customer does not own the ATM (the rent or lease the space for the ATM)? I can conduct a review if the customer conducts ATM transactions through the bank. But what do other banks do when ATM transactions are not conducted at the bank? Basically the customer just rents space and another company handles the ATM transactions/processing/refilling, etc...

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#2156503 - 12/07/17 07:32 PM Re: Privately Owned ATM Question Megaman
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
Get a copy of the contract to prove they do not have anything to do with the machine, replenishing the cash, etc. It will mitigate the money laundering risks of the machine being in the store.
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