Can anyone give me some guidance on BSA requirements regarding a coin machine in our lobby? The coin machine is available to non-customers. Coin is run the the machine and the non-customer gets a receipt to take to the teller window to obtain the cash. Are we required to ID that non-customer and run OFAC?

We have a coin machine also that customers and non-customers can use and we charge non-customers a fee, but we do not ID or run an OFAC on them. We accept the risk and this is not even mentioned in my BSA manual. Our process is the same as yours, they get a receipt and take to the teller window and get the cash.

you are not required to run an OFAC scan on anyone, it is a risk based decision and process on what you choose to review, but there is no mandate from OFAC that you MUST run checks (now, pay someone on the list and you may be in deep stuff, but that is another story). essentially all you are doing is trading one form of currency for another, not making payments between parties. While we don't do this for non-customers, if we did i don't believe i'd be asking for ID either (unless the same guy is in 3+ days a week or more with heavy coin volume clearly using it to take advantage of the free service or doing what i thought was suspicious)

Thank you for your input, I appreciate it. I am wondering if you track these same transactions for customers? IMO we should be aggregating these with their other daily transactions.

Yes as a currency exchange.

Can you lead me to a specific reg name? I'm dealing with this currently and need to have support...

They give you coins, you give them bills.

Sec. 1010.311 Filing obligations for reports of transactions in currency.

Each financial institution other than a casino shall file a report of each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution which involves a transaction in currency of more than $10,000, except as otherwise provided in this section. In the case of the U.S. Postal Service, the obligation contained in the preceding sentence shall not apply to payments or transfers made solely in connection with the purchase of postage or philatelic products.

Gotcha. I misread that as requiring an OFAC check for coin exchanges. I knew the CTR piece. Thanks.

Just curious.....why are you offering this service to non-customers?

Fee income I'm guessing?

I can't imagine that any fee income generated is worth all the things that have been discussed here.

Just my personal opinion.