Are All Private ATM Owners Equal

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Question:

I have read through several articles on private ATM owners and the enhanced due diligence on these; however, none seem to call out private ATM owners that do not have access to fill the ATM. Would these customers have the same expectations? Would it be necessary to tag these customers, obtain contracts/agreements and do yearly reviews of activity?

Answer:

If the activity is not going through your customer's account, there is minimal due diligence that can be done. Many institutions request copies of the lease agreement to verify that a third party owns and services the ATM to ensure that your customer isn't using a different bank for the ATM settlement and then depriving you of the full picture of the relationship. The only activity there would be to review is a monthly lease payment so while it is good to know who these customers are so you can keep track of any changes in the risk profile (e.g. the customer begins servicing the machine themselves later on) that doesn't automatically make the customer high risk today.