Overview

Privately-owned ATM machines (PATMO) are those that are not owned by Capital City Bank. These ATMs are often associated with cash-intensive businesses. A lack of controls on how currency is placed in PATMO makes them particularly susceptible to money laundering and fraudulent activities. 

The Bank Secrecy Act and Anti-Money Laundering regulations require banks to conduct extensive monitoring of the cash and transactional activity in such accounts. One of the objectives of the required monitoring is to determine the source and use of funds flowing through these accounts. The bank is not able to properly identify the exact source and use of the cash activity within accounts when retail sales funds are commingled with check cashing, Automated Teller Machine (ATM), and Money Service Business (MSB) funds.

Bank Secrecy Act (BSA) officer approval is required to open accounts for clients identified as ATM service providers. CCB requires these special account types to have independent accounts for all transactions pertaining to the private ATM transactions. These independent accounts ensure the separation of funds from everyday operating expenses.  

Account Opening - Approval Process

Associates and officers MUST obtain BSA officer approval prior to opening an account for a prohibited entity, product, service or a restricted client type.

If the client opening a new business account is identified as an ATM service provider, to obtain BSA approval do the following:

1. If applicable, complete a Money Services Business (MSB) /Check Casher (CC) Agreement or Privately Owned ATM (PATMO) Account Request form. 
2. E-mail the completed agreement or form to _BSA Department.
3. Include details about the client and any relationship details.
4. If the BSA officer approves the account opening, print the approval email.
5. Include the printed email approval from BSA and the completed MSB/CC Agreement or PATMO Account Request form with the new account documents. 

Note: PATMO accounts are opened in the Commercial Business Checking account type.

For additional account opening details see Specific Business Entity Requirements.