ATM Compliance & Operator Resource Portal

What you need: An Arizona LLC protects your personal assets from business liabilities. It’s the standard structure for independent ATM operators.

How to file

1. Go to the Arizona Business Center at abc.azcc.gov
2. Select “File a New LLC” and complete Form L010 — Articles of Organization
3. Pay the $50 filing fee

Processing times

• Standard: 14–16 business days
• Expedited: $85 (3–5 days), $150 (next day), $250 (same day), $450 (2 hours)

Name requirements

Your entity name must include “Limited Liability Company,” “LLC,” or “L.L.C.” per ARS § 29-3112. Search existing names at abc.azcc.gov before filing.

Publication requirement

Maricopa County (Phoenix, Scottsdale, Chandler, Tempe, Mesa, Gilbert, Glendale, Peoria, Surprise) is exempt from the newspaper publication requirement under ARS § 29-3201(G). The Arizona Corporation Commission publishes your filing automatically.

Counties with population under 800,000 must publish in a newspaper for 3 consecutive weeks within 60 days of approval.

After approval

• No annual report required — significant advantage over corporations
• Amendments required within 30 days of any member, manager, or address changes ($25 fee)
• Statement of Change for agent or address: $5

What you need: An Employer Identification Number from the IRS. Required to open a business bank account, sign a processor agreement, and file taxes.

How to apply

1. Go to irs.gov and select “Apply for an EIN Online”
2. Complete the application — it takes about 10 minutes
3. Your EIN is issued instantly

Requirements

• Available Monday–Friday, 7:00 AM – 10:00 PM Eastern Time
• You must have your LLC approval first
• Free — no cost to apply

What you need: An internal governance document that defines ownership, management authority, capital contributions, distributions, and dissolution procedures.

Why it matters

Arizona law does not require an operating agreement for LLCs. However, you will need one to:

• Open a business bank account (most banks require it)
• Apply for a processor account
• Maintain liability protection (courts may disregard the LLC without one)
• Apply for insurance

What to include

• Formation purpose and principal office address
• Member information and ownership
• Management structure (member-managed)
• Capital contributions
• Distribution and tax treatment
• Dissolution triggers and winding-up procedures
• Amendment process

What you need: ATM operators are classified as Money Services Businesses (MSBs) under federal law. You must register with the Financial Crimes Enforcement Network (FinCEN).

How to register

1. Go to the BSA E-Filing System at bsaefiling.fincen.treas.gov
2. Create an account and file FinCEN Form 107
3. Submit — registration is free

Deadlines

• Must file within 180 days of commencing ATM operations
• Renew every 2 years by December 31
• Retain documentation for 5 years at a U.S. location

What you need: A written Bank Secrecy Act / Anti-Money Laundering compliance program. Required for all registered MSBs.

Five required pillars

1. Internal policies and procedures — Written rules for transaction monitoring, cash handling, and suspicious activity identification
2. Designated compliance officer — A named individual responsible for day-to-day compliance
3. Employee training — All employees who handle cash or monitor transactions must be trained within 30 days of hire
4. Independent annual review — An outside party reviews your program annually ($500–$1,000/year)
5. Recordkeeping — Maintain all compliance records for a minimum of 5 years

Filing obligations

• CTR: Required for cash transactions exceeding $10,000 in a single day. File within 15 calendar days.
• SAR: Required within 30 calendar days for suspicious patterns. SARs are confidential and must never be disclosed to the subject.

What you need: A business insurance package that covers your ATM equipment, the cash inside, and the cash in transit.

Required coverage

What you need: A dedicated business checking account for receiving processor settlement deposits and withdrawing cash for ATM fills.

What to bring

• LLC Certificate of Organization
• EIN confirmation letter
• Signed Operating Agreement
• Government-issued personal ID
• Proof of business address

Where to apply in Arizona

Credit unions tend to be more MSB-friendly than large national banks.

• Desert Financial Credit Union — Largest AZ credit union, 50+ branches
• OneAZ Credit Union — No monthly fee business checking
• Arizona Financial Credit Union — Local, MSB-aware
• TruWest Credit Union — Tempe/Scottsdale area
• First Fidelity Bank — Confirmed ATM-friendly
• National Bank of Arizona — Zions Bancorporation subsidiary

What you need: A payment processor connects your ATM to the card networks, handles transaction authorization in real-time, and settles funds via ACH.

What to evaluate

• Terminal Management System (TMS) — the #1 differentiator at scale
• Per-transaction fees ($0.00–$0.35)
• Monthly minimums ($25–$50)
• Contract length — prefer month-to-month or 1-year
• Vault cash options

Red flags

• Setup fees (should be $0 in 2026)
• Contracts longer than 2 years with auto-renewal
• Early termination fees calculated as remaining contract value
• Unclear interchange pass-through fees

What you need: A written contract between you and the business owner where you’ll place the ATM.

Seven key clauses

1. Parties and contact information
2. Location and placement — exact address and placement inside the business
3. Surcharge fee — amount and how it can be changed
4. Revenue split — owner share and payment schedule
5. Responsibilities — your scope vs. business owner’s scope
6. Term and cancellation — typically 1–2 years, 30 days notice
7. Liability and insurance — separate coverage and indemnification

Best location types in Arizona

• Bars and nightclubs — highest per-machine revenue
• Convenience stores and gas stations — steady volume
• Restaurants — especially cash-heavy cuisines
• Laundromats — low but consistent volume
• Smoke shops and vape shops
• Auto repair shops
• Cannabis dispensaries — cash-only operations

The pitch

“We place a free ATM in your business. We handle everything — installation, cash loading, maintenance, and service. You provide a power outlet and floor space. You receive $[amount] per transaction, paid monthly. There is no cost to you.”

Regulation E — Surcharge Disclosure (Federal)

Two notices are required by law before every surcharge transaction:

1. Physical notice on or near the ATM
2. On-screen notice shown before the consumer commits, with cancel option

ADA Compliance (Federal)

• 30″ × 48″ clear floor space in front of the ATM
• Maximum 48″ operable height for controls
• Tactile keypad with raised dots on the “5” key
• Braille labels on function keys
• Audio output via standard headphone jack

PCI DSS (Industry Standard)

• Install tamper-evident seals on the ATM vault
• Inspect for skimming devices at every service visit
• Use TR-31 key block standard (mandatory since January 1, 2025)
• Report any suspected compromise to your processor immediately