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Privately Owned ATM in Business-MSB?

Question: 
If a business customer has a privately owned ATM in their business, are they considered an MSB?
Answer: 

by Andy Zavoina:

For the in-depth definition, use this link and scroll to (ff).

In short, I don't see a common ATM triggering the business as being an MSB, but you need to know what is happening behind the counter - what services does the business offer which may make them an MSB:

1. Money Orders- Issuer of money orders, Seller of money orders, Redeemer of money orders
2. Traveler's Checks- Issuer of traveler's checks, Seller of traveler's checks, Redeemer of traveler's checks
3. Money Transmission- Money transmitter
4. Check Cashing- Check casher
5. Currency Exchange- Dealer in foreign exchange
6. Currency Dealing- Dealer in foreign exchange
7. Prepaid Access- Provider of Prepaid Access, Seller of Prepaid Access

You may find this free BOL Tool helpful as it helps with BSA compliance when a private ATM is in a business. https://www.bankersonline.com/tools/42716

Answer: 

by Brian Crow:

FinCEN issued guidance in 2007 that clearly states a buisness's owning or operating a privately owned ATM does not make the business a money transmitter since people are withdrawing their own money.

First published on 03/24/2019

Filed under: 
Filed under compliance as: 

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