Can Use of a "Cashless ATM" Be Considered Money Laundering?

An interesting question was raised last week during a meeting of ATMIA’s U.S IAD Committee – could the providers and merchants using so-called “cashless ATMs” be considered to be participating in Money Laundering?

The U.S. Department of the Treasury website provides the following definition of Money Laundering:

Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit activities. Money laundering facilitates a broad range of serious underlying criminal offenses and ultimately threatens the integrity of the financial system.

Arguments can be made on both sides of this question, but the function of a cashless ATM is to disguise a transaction that is not permitted by the ATM networks. Which certainly seems to track very closely to the definition above.