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Question of the Week
Posted: Jul 28, 2022 | Author:
Cornerstone Compliance Team
ATM
compliance
FinCEN
Question: If a member runs an ATM at their business, does that make them a money transmitter?
Answer: No. FinCEN addressed this matter in a 2007 opinion that if an owner-operator of an ATM only allows a person to access their account without the ability to send those funds to other persons, that owner-operator is not a money transmitter.
See the opinion here: https://www.fincen.gov/resources/statutes-regulations/guidance/application-definition-money-services-business-certain
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