Attention Pawnbrokers Who Independently Own or Operate ATMs
I often see discussions regarding the pros / cons of having an ATM in your stores. The availability of an ATM is a convenience for customers intending to redeem their pawn and forgetting they need cash to do so is one example.
Banks will hopefully see the clarity intended in this FinCEN statement that not all independent ATM owners and/or operators should be automatically looked at as a higher risk.
If you are an independent ATM owner or operator you already know that you are subject to BSA/AML regulatory requirements. The CDD (Customer Due Diligence) requirements section is very clear, as is this entire FinCEN statement.
You may wish to keep this statement on hand for future communications with your financial institution. Personally, I do not see why the same clarity would not apply to your pawn operations, as well.