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#2215435 - 06/11/19 07:17 PM Privately Owned ATMs
IUalum Offline
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Kentucky
What do you guys look for when trying to identify customers who have privately owned ATMs, particularly if the customer is not providing the cash to stock the ATMs? Are there certain types of transactions you look for in their account activity? Specific vendors or amounts?
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#2215436 - 06/11/19 07:24 PM Re: Privately Owned ATMs IUalum
rlcarey Offline
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Galveston, TX
How are they stocking them would be my first question.
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#2215437 - 06/11/19 07:32 PM Re: Privately Owned ATMs IUalum
IUalum Offline
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Our customer is not providing the cash. The owner of the ATM stocks it and our customer receives a percentage of the withdrawal fee income.
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#2215444 - 06/11/19 07:52 PM Re: Privately Owned ATMs IUalum
P*Q Offline

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Our AML software informs us of unidentified ones based on transactions going through the account. Otherwise we require annual on-site visits of cash intensive businesses or businesses that would typically have an ATM and one of the questions is to see if there's an ATM there, if so, we gather additional due diligence info.

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#2215479 - 06/11/19 09:39 PM Re: Privately Owned ATMs IUalum
rlcarey Offline
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So, they are renting space for the ATM and otherwise have nothing to do with it??
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#2215499 - 06/12/19 12:42 PM Re: Privately Owned ATMs IUalum
IUalum Offline
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Kentucky
Yes, except for a percentage of the income.
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#2215526 - 06/12/19 02:57 PM Re: Privately Owned ATMs IUalum
Q Offline
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Joined: Jun 2015
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We have key word searches in our system: Cash Depot, Worldpay, Elan, etc. We used to do it manually but now our AML system does it for us. If we find one we did not know about we reach out to account officer to fill out a checklist and do a site visit. As far as situation with customer renting space for an ATM that is on the ATM owner's bank on how they fill the machine. We would simply ask our customer for copy of rental agreement.

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#2215529 - 06/12/19 03:03 PM Re: Privately Owned ATMs IUalum
IUalum Offline
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Thanks, everyone.
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#2215555 - 06/12/19 04:21 PM Re: Privately Owned ATMs Q
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Originally Posted By Q
As far as situation with customer renting space for an ATM that is on the ATM owner's bank on how they fill the machine. We would simply ask our customer for copy of rental agreement.
Ditto. We still require an annual site visit though to confirm ownership and servicing arrangements haven't changed and to also confirm that they didn't become say an MSB since the last site visit.

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