FINTRAC’s New AML Obligations for Private Automated Banking Machines
Why Private ABMs Are Now Regulated
Private or “white-label” automated banking machines (ABMs) are a convenient cash access point, but they have also been flagged by regulators as a high-risk channel for money laundering. To close that gap, the government has made acquirers of private ABMs subject to FINTRAC oversight starting October 1, 2025.
This move brings private ABM operators and acquirers into the same compliance framework as money services businesses and other financial entities. From that date, acquirers will be responsible for building and maintaining AML compliance programs, monitoring transactions, and reporting suspicious activity to FINTRAC.
What the New Obligations Mean for Acquirers
As reporting entities, private ABM acquirers must comply with the full suite of FINTRAC requirements, including:
Compliance program design with a compliance officer, policies, risk assessments, training, and ongoing review.
Client due diligence including politically exposed persons (PEPs) and heads of international organizations (HIOs) checks.
Suspicious transaction reporting (STRs) and, where relevant, listed terrorist property reporting.
Detailed recordkeeping of client identification, transactions, reconciliations, and risk assessments.
Independent effectiveness reviews to confirm programs are working as designed.
An AML Compliance Officer to oversee the AML compliance program
The ability to file STRs and conduct PEP checks represents a big cultural shift for many acquirers, who may never have interacted with FINTRAC before.
The Common Pitfalls Ahead
Acquirers will likely face challenges in building systems capable of detecting unusual activity across multiple ABMs, particularly when machines are distributed across varied geographic or retail environments. Recordkeeping and reporting workflows are often fragmented, leaving gaps in the information FINTRAC requires. Training is another hurdle, employees and contractors working in cash-intensive businesses often have little exposure to compliance obligations.
How Platino Consulting Works with Private ABM Acquirer Services
Platino Consulting works with private ABM acquirers to design and implement compliance systems that are proportionate, efficient, and regulator-ready. Our services include:
Registration and onboarding support: Ensuring your business is registered with FINTRAC and properly classified.
Program development: Drafting AML policies, risk assessments, and procedures tailored to the ABM business model.
PEP/HIO screening solutions: Implementing scalable systems to identify high-risk clients.
Reporting frameworks: Building processes for suspicious transaction detection and reporting, with sample STR templates.
Independent reviews: Conducting effectiveness reviews and preparing you for potential FINTRAC examinations.
Training: Delivering staff and contractor training that is accessible and practical for ABM operators.
Fractional AML Compliance Officer support: Meeting the FINTRAC requirement for an AML Compliance Officer and providing on-going AML compliance support.
With Platino Consulting as your compliance partner, acquirers can meet their new obligations without disrupting day-to-day business operations.
Preparing for the Transition
The October 2025 deadline is not far away, and regulators will expect compliance programs to be in place from day one. By acting now, acquirers can spread the workload, test their systems, and avoid last-minute pressure.
Platino Consulting offers structured readiness roadmaps to help private ABM operators meet every element of the FINTRAC regime.
