Privately Owned ATM

Posted By: Jenny Roberts

Privately Owned ATM - 04/16/20 02:32 PM

I have a customer that says he funds an ATM machine for a convenience store but he doesn't own it. He says there is no contract between them for him funding the ATM. He is funding it out of a personal account....wouldn't there need to be a contract of some sort between them? Seems suspicious to me....

I also have a customer that owns a gas station and he says he funds the ATM there but doesn't own it. I have tried for over a month to get him to bring in a copy of a contract but he is avoiding me.....what can I do to show that I am attempting to resolve this for auditor and can we close his account if he doesn't comply?

Where can I find more information on privately owned ATMs please?

Posted By: rlcarey

Re: Privately Owned ATM - 04/16/20 02:42 PM

The real question on both of these is how are they getting paid back?

If you cannot get a reasonable explanation that you can verify, I would be closing the accounts.
Posted By: Buddy the Elf

Re: Privately Owned ATM - 04/16/20 04:51 PM

The FFIEC Examination Manual has information on the money laundering risks associated with privately-owned ATMs. The National ATM Council website has published a document called Industry Guidelines for ATM Vault Cash and Settlement Accounts that you may find helpful also.
Posted By: Jenny Roberts

Re: Privately Owned ATM - 04/16/20 06:50 PM

They have ACH deposits that are coming into their accounts.
Posted By: Jenny Roberts

Re: Privately Owned ATM - 04/16/20 07:00 PM

Thank you!
Posted By: JennKK2

Re: Privately Owned ATM - 04/22/20 08:51 PM

so funny how this thread came up as i was just working on this. our FDIC examiners wanted a bit more due diligence done on our customer who has a privately owned ATM so we are using a checklist provided by an AML training i attended. however looking for a little more light on the subject:
1. our customer owns the ATM v.
2. our customer has an ATM on the property which they do not own.

so do we need to request an agreement from the customer in both scenarios or just the first one?
Posted By: rlcarey

Re: Privately Owned ATM - 04/22/20 09:09 PM

Depends on your risk assessment. Usually always on the first one - you may or may not ask on the second depending on the customer and who the owner of the ATM might be.
Posted By: JennKK2

Re: Privately Owned ATM - 04/23/20 04:23 PM

long term customer of the bank so there is no concern there, but asking them about the owner of the ATM, well some don't want to approach the customer on the ATM information due to the customer having removed the bank's years ago for a better deal with the one they have now...i guess they feel "bad"?

but agree the bank's risk assessment of how we approach this situation would clarify things...but again that is what we are developing / improving