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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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