Vault cash account

Definition

The bank account a route replenishes from, which is the permission this trade actually runs on.

Why It Matters

The compliance question here is the opposite of the one buyers expect. An independent operator dispensing its own vault cash sits outside the federal money services business definition, because that definition turns on accepting value from one person and transmitting it to another and a cash machine does neither, so there is no federal registration to hold and none to transfer. The problem is keeping a bank account. The agency's guidance on this trade is addressed to BANKS about their own diligence, never to the operator, and it lists what a bank may ask for: the currency servicing arrangements and contracts, and the source of funds where the account is not what replenishes the machines. A route filled from anything other than a bank withdrawal is the route whose banking is fragile. Minnesota licenses per machine and says nothing about a transfer.