We have a new business customer that is known by one of our personal bankers. He (or his business?) owns some ATMs (not sure how many machines he or his business owns). Each week he wants to come into the bank and cash a check for $10,000 (exactly $10,000) and receive all $20 bills to restock his machines. He deals with several banks. Has anyone had this type of business (privately owning ATMs) customer? Is this normal procedure (regularly cashing a large check for $20s)? I would like to check to ensure he has these ATMs, but beyond that can you think of any other due diligence we should be performing to "know our customer"? Thank you.

Your suggestion that you'd like to verify that he runs the ATMs is an excellent one. I would suggest you obtain a list of the locations. Then, I'd suggest you consider visiting these machines occasionally to see if it appears they are doing any business. Unless transaction numbers are assigned centrally, you can often get a sense of activity by pulling a balance inquiry and noting the transaction sequence number printed on the "receipt." Do the same thing a week later to get a feel for the number of transactions done per week. Then based on what you might know about average withdrawal amounts in your area, do a guesstimate of cash use.

ATM transaction volume should vary by season and from week to week. It's unlikely that exactly $10,000 would be used each week. So the withdrawal pattern you've described seems suspect, particularly because it's only $0.01 below the CTR threshold.

We had a customer who also replenished ATM cash machines he owned. THe problem we discovered was that all these ATM machines were located in these illegal gambling rooms/buildings, with blacked-out windows and doors, and to enter the place, there were door buzzers. These illegal gaming rooms had those 8-liners which are not allowed in Texas.

Be cautious of this business as John suggests and do plenty of due diligience to see if this business is on the level.

- The BOL User

I had another thought. You said your ATM-owning customer does business with several area banks. My inference is that he might be doing the large withdrawal "thing" with more than your fine institution.

This might be a great case for a §314(b) discussion with your peers at the competition to see if perhaps the combined activity of this person looks even more suspicious that you think based on your own bank's experience.

Unless the ATMs are in isolated areas, I don't think that $10,000 per week would be enough for one ATM, much less several, at least not compared to our (rural) usage.