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. FinCEN's 2007 guidance says a nonbank operator offering only balance inquiries and withdrawals, and stocking the machine from its own account, is not a money services business. The machine dispenses the cardholder's own funds on the bank's authorization and cannot send money to a third party, so there is no FinCEN registration to hold and none to transfer. The problem is keeping a bank account. The federal bank examiners' manual has a section on these customers, written about the bank's diligence and not the operator's. It lists what may help a bank: the currency servicing arrangements and contracts, and the source of funds where the account does not replenish the machines. It rates a route filled only with cash withdrawn from its bank account at relatively lower laundering risk, and one filled from other or unknown cash as potentially higher. Minnesota requires its commissioner to approve each terminal a nonbank establishes, though one application may cover several locations, and its approval section says nothing about a transfer.