FinCEN’s recently released statement on BSA Due Diligence for Independent ATM Owners and Operators make it abundantly clear that their primary concern is knowing the source of cash. While the 2021 exam manual has a similar section, “Risk Factors”, that mentions the lack of a consistent regulatory environment, this recent FinCEN statement does not. When comparing the 2014 exam manual, the updated 2021 version, and this new FinCEN statement, they all place a clear emphasis on cash sourcing.

In this “Compliance Quick Bite”, our Director of BSA/AML Services, Matthew Hovis, CAMS, CFE, CPP, provides a brief update on the FinCEN statement and shares best practices for your institution.


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