Regulatory Alerts2007-12-03
Added
Application of the Definition of Money Services Business to Certain Owner-Operators of Automated Teller Machines Offering Limited Services
Non-bank owner-operators of automated teller machines (ATMs) that provide only remote account access for balance inquiries and currency withdrawals are not considered money services businesses (MSBs) under the Bank Secrecy Act. These entities do not qualify as currency dealers or exchangers because they do not buy or sell currency, nor as money transmitters because they do not accept or transmit funds to third parties. The guidance specifies that the ATM acts solely as a terminal communicating withdrawal instructions authorized by the customer's depository institution, with funds dispensed from the owner-operator's own account.
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