Answer:
Not necessarily. The FFIEC manual was updated in 2021 to reflect updated due diligence considerations for potentially higher-risk customers, such as independent ATM owner/operators. The risk is dependent factors such as the number and geographic location of ATMs, cash activity levels, and source of funding. An ATM located in a gas station belonging to a long time customer poses a lower risk than a business owning multiple ATMs in higher-risk geographies where the funds to fill the machine is not obtained from your institution.
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Learn more about Robin Guthridge’s, Mastering High Risk Monitoring webinar.
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