New FinCEN Statement on IAD Fraud Risk

On June 22, 2022, FinCEN (Financial Crimes Enforcement Network, U.S. Department of the Treasury) released their "Statement on Bank Secrecy Act Due Diligence for Independent ATM Owners or Operators".  That statement notes the issues that many IADs have had with getting and keeping the bank relationships that are necessary to operate their business –  which "jeopardizes the important financial services they provide, including to persons in underserved markets".

"FinCEN reminds banks that not all independent ATM owner or operator customers pose the same level of money laundering, terrorist financing (ML/TF), or other illicit financial activity risk, and not all independent ATM owner or operator customers are automatically higher risk."

This recent statement essentially emphasizes the guidance provided in the independent operator section of the revised BSA/AML examination manual.  The implementation of a risk-based approach is required for all bank customers.  It also lists the types of information that the bank may wish to collect in making CDD decisions.

A full copy of the FinCEN statement may be downloaded from the ATMIA USA website home page.   For more information about ATMIA advocacy efforts, contact USA executive director, David Tente.  The ATMIA Operation Choke Point Resource Kit can be downloaded here.

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