FinCEN issues a statement to provide “clarity” to banks on how to apply a risk-based approach to conducting CDD on independent ATM owners or operators in line with the requirements set out in FinCEN’s 2016 CDD Rule

Financial crime risk for independent ATM owners or operators varies based on transaction volume, ATM locations, and fund source. Bank-funded ATMs may pose a low risk due to bank knowledge and ability to identify suspicious activity…