Inflation Reduction Act: Highlights of Key Changes for You and Yo...
2022-2023 Tax Planning Guide
VIEWpoint Issue 1 | 2022
On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a statement clarifying how to conduct customer due diligence on independent ATM owners and operators. FinCEN felt the statement was necessary because some independent ATM owners and operators have encountered difficulties in obtaining and retaining banking services.
An independent ATM operator is an individual or an entity that is in the business of owning, leasing, managing or otherwise controlling access to the interior of an ATM, including its internal cash vault. FinCEN states not all independent ATM owner or operator customers pose the same level of money laundering, terrorist financing or other illicit financial activity risk, and not all of them are automatically higher risk. Also, if banks (and credit unions) comply with the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) requirements and appropriately manage risks, they are not prohibited or discouraged from providing services to independent ATM owners and operators.
Financial institutions must apply a risk-based approach to customer due diligence (CDD) in developing the risk profiles of their customers or members, including independent ATM owners or operators, and are required to establish and maintain written procedures reasonably designed to identify and verify beneficial owners of legal entity customers. The CDD rule does not require financial institutions to conduct additional due diligence or to institute due diligence processes unique to independent ATM owner or operator customers. The statement suggests that financial institutions collect the following information for independent ATM owners and operators:
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
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