Can someone tell me exactly what I need to do as far as BSA for our business customers who own their own ATMs?

We tell our businesses who own an ATM that they need to register annually with the state banking department

We have forms available if they can't get their own online

How do I know if they've actually registered? Or do I have to know?

We have less than 20 who own their own, other's are leasing or set up on commission

As part of our enhanced customer due diligence on privately owned ATMs, we are requesting the confirmation from the state of OK that they have filed. It is also required to be renewed annually, so we request that too.

As for monitoring for AML, there are several resources that provide red flags to watch for on privately owned ATM accounts. Primarily, you want to know how they are funding the ATM. If they are using their own funds from a source other than their bank account, there is a good chance that money laundering could occur. Also compare the ATM cash outs with the ACH credits, for the same reason.

Hope that helps!

Thank you "Frog Lady" that does help