The ATM industry in the United States is facing many challenges. For one, the interchange rates that networks pay to ATM owners have been halved over the last five years, transaction surcharges are topping off, and operating expenses are escalating. These financial strains may be hardest for the thousands of small business entrepreneurs in the United States who own and operate ATMs independent of those that belong to financial institutions (FIs). (Non-FI owners/operators are responsible for an estimated 65 percent of all U.S. ATMs.) For another, at least for the small-business independents, a changing landscape is placing pressure on the relationships the independent owners/operators have with their FIs.
I recently attended and spoke at the National ATM Council's (NAC) annual conference. NAC is a nonprofit national trade association that represents the business interests of these non-FI ATM owners and operators. During the conference, I spoke with many of the attendees to learn more about the key drivers and concerns of their business. The biggest concern many owners/operators expressed is their sponsoring FI will classify them as a high-risk business and terminate their banking relationship. (Many FIs are in the process of "de-risking" their portfolios.) FIs may mistakenly classify these operators as money service businesses (MSB), since they dispense cash, even though state regulators do not consider them as such. Two factors are contributing to this confusion: guidance from the FFIEC's examiner manual that cautions financial institutions that criminals can use ATMs to launder funds, and an organizational structure that has sub-ISOs (that is, independent sales organizations), which can make ownership of all the ATMs unclear.
In actuality, the ability of ATM operators to launder money through an ATM is quite restricted beyond the initial funds placed in the terminal. The processors and networks, which are totally independent from the owners, generate financial reports that show the amount of funds that an ATM dispenses in any given period. So if the reports show an ATM paid out $5,000 in a month, the ATM owner can only justify resupplying the ATM with $5,000, plus a little reserve. In other words, controls maintained by independent parties clearly document the funds flowing through the ATM. Additionally, the non-FI sponsorships are dominated by four highly regarded financial institutions with strict AML/BSA programs that validate the initial funding of the ATM and monitor ongoing activity.
My advice to the group to try to avoid having their business relationship questioned or, worse, terminated, was to work proactively with the financial institution providing their settlement service and cash supply needs. Make sure their account officers understand how their businesses operate and know the controls that are in place to make money laundering unlikely to happen. And if you work for an FI that works with non-FI ATM owners/operators, don’t be surprised if they come calling on you.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed