IBA Compliance Connection

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Now that the nonbank ATM registration requirements have been repealed, should we change our BSA risk or monitoring procedures for customers that own nonbank ATMs?

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No, we do not recommend changing your current BSA and monitoring practices for customers that own nonbank ATMs. These customers are no longer required to file statements of ownership with the Illinois Department of Financial Regulation (IDFPR), but this should not affect your bank’s risk assessment of these customers. If your bank has determined that these customers warrant monitoring or other risk mitigation procedures due to the BSA risks that they pose, we recommend continuing with those approaches.

For resources related to our guidance, please see:

  • Public Act 100-5 (Repealing the requirement to notify and file statements of ownership with the IDFPR for nonbank ATMs, as of June 30, 2017.)
  • Illinois Electronic Fund Transfer Act, 205 ILCS 616/30(B) (As of June 30, 2017, requiring that nonbank ATMs “post a telephone number on the terminal for consumers to call to report problems, along with the Department’s telephone number.”)