Welcome to Spodek Law Group. Our goal is to give you the reality of what happens when federal investigators target your ATM business for money laundering - not the sanitized version other lawyers present, not the "everything will be fine" fiction, but the actual truth about how the federal government builds cases against ATM operators and why your legitimate business might already be generating the evidence they need to prosecute you.
The cash-intensive nature of ATM operations makes you inherently suspicious to federal investigators. Not because you did anything wrong. Because the system is designed to view high-volume cash businesses as money laundering vehicles until you prove otherwise. And by the time you get the chance to prove anything, they've been watching for months.
Here is what nobody tells ATM business owners until its too late: the very success of your cash operation creates the documentation trail that federal prosecutors use to build their case. Every transaction you process, every Currency Transaction Report filed, every pattern in your daily deposits - all of it feeds into FinCEN databases where sophisticated pattern-matching algorithms flag "suspicious" activity long before any human ever reviews your file.
Why Your Cash Business Makes You a Federal Target
If your running an ATM business, you need to understand something fundamentaly important. The federal government views cash-intensive businesses with automatic suspicion. Not because of anything you specifically did. Because cash businesses are how money gets laundered, and the government has built an entire infrastructure designed to monitor, analyze, and prosecute cash business operators.
Money laundering prosecutions have increased 45% since 2020. Thats not a typo. The DOJ has made financial crimes a priority, and ATM operators are squarely in there crosshairs. According to U.S. Sentencing Commission data, there were 1,095 money laundering cases in fiscal year 2024 alone.
Think about what that means for you.
Every ATM transaction over $10,000 triggers a mandatory Currency Transaction Report filed with FinCEN. Every single one. These reports dont just sit in a filing cabinet somewhere. They feed into massive databases where artificial intelligence pattern-matching software analyzes transaction flows across the entire financial system. The software looks for patterns. Structuring patterns. Velocity patterns. Geographic patterns.
Your bank is required to report you. Thats not hyperbole - banks face up to $200 million in penalties for BSA/AML violations. When they see anything remotley suspicious in your account activity, they file a Suspicious Activity Report to protect themselves. Your banker isnt your friend in this situation. Your banker is your first accuser.
As Todd Spodek has explained to dozens of clients facing federal money laundering investigations, the system is designed to build cases automaticaly. You dont have to do anything wrong. You just have to run a succesful cash business.
The MSB Registration Nightmare
Before we even get to the actual money laundering issues, lets talk about registration. If you operate ATMs and handle cash, you are almost certainy required to register as a Money Services Business with FinCEN. Not registering is itself a federal offense.
The registration deadline is 180 days from the start of operations. Miss it? Civil penalties of $5,000 per day start accumulating. Every single day you operated without registration becomes a seperate violation. If you've been running unregistered for two years, thats potentialy over $3.5 million in civil penalties alone - before anyone even looks at criminal charges.
But heres the trap within the trap.
Registering as an MSB triggers mandatory Anti-Money Laundering compliance requirements. You need a written AML program. You need a designated compliance officer. You need employee training. You need suspicious activity monitoring and reporting procedures.
Not registering is a crime. Registering without proper compliance is a crime. The federal government has created a regulatory maze where every path leads to potental prosecution.
Think about the math here. If your competing with operators who cut corners on compliance, your at a disadvantage. Your costs are higher. Your profits are lower. But if you cut corners to compete, your creating exactly the evidence federal prosecutors need to destroy you.
There is no winning move except perfect compliance - and perfect compliance is effectivly impossible in a cash business where you cant control what customers do.
The Structuring Trap Nobody Warned You About
Heres were most ATM operators make their fatal mistake.
You probably know about the $10,000 CTR threshold. So when a customer asks to break up a large transaction into smaller pieces - maybe three deposits of $8,000 instead of one deposit of $24,000 - you might think your being helpfull. Your making things easier for everyone. No paperwork hassle.
Stop.
What you just did is called "structuring" and its a federal crime under 31 USC 5324. The act of breaking up transactions specificaly to avoid Currency Transaction Report requirements is itself illegal. Not the money laundering. Not the underlying crime. The avoidance of the paperwork is the crime.
Read that again.
You dont need dirty money. You dont need criminal customers. You dont need any connection whatsoever to actual illegal activity. If you help someone avoid CTR filings - even a completley legitimate customer with completley legitimate funds - you have commited a federal offense carrying up to 5 years in prison.
The 1994 Money Laundering Suppression Act made this crystal clear. The government doesnt need to prove you knew structuring was illegal. They only need to prove you knew about the CTR reporting requirement - which, as a registered Money Services Business, you absolutly do - and that you helped someone avoid it.
If you have EVER processed transactions designed to stay under $10,000, you need to speak with a federal defense attorney immediately.
What Happens Before You Ever Get a Target Letter
Heres the thing most people dont understand about federal investigations. By the time you recieve a target letter, the investigation has been running for months. Sometimes years.
Grand jury investigations are secret. The FBI and IRS-CI have been subpoenaing your bank records, your armored car service records, your vendor contracts. Theyve been talking to your employees - some of whom may already have immunity deals in exchange for there cooperation. Theyve been analyzing every CTR and SAR associated with your business going back years.
You didnt know any of this was happening. Meanwhile they were building their case.
The average money laundering investigation runs 12 to 24 months before the target ever recieves notification. Think about what that means. By the time you find out theres even a problem, federal prosecutors have already reviewed thousands of transactions, interviewed multiple witnesses, and mapped out exactly how they plan to present the case to a jury.
The deck is stacked. Thats not pessimism - its mathematics. Federal conviction rates exceed 90% becuase prosecutors only bring cases they are confident they will win. If you've recieved a target letter, they beleive they have enough evidence already.
Your armored car service? Potentialy a cooperating witness. Your cash supplier? Potentialy a cooperating witness. Your bank? Definately filing defensive SARs to avoid their own liability. Everyone in your business ecosystem has incentive to cooperate with the government against you.
How Your Compliance Program Becomes Exhibit A
OK so heres the irony that keeps defense attorneys up at night.
You did everything right. You registered as a Money Services Business with FinCEN. You developed an Anti-Money Laundering compliance program. You trained your employees. You documented all your procedures. You thought you were protecting yourself.
You were actualy building the prosecution's case.
When federal prosecutors charge you with money laundering, they will introduce your compliance documentation as evidence. Not evidence that you were compliant. Evidence that you KNEW the rules. Your training materials prove you understood what constituted suspicious activity. Your written procedures prove you knew exactly what you were supposed to do.
And when something went wrong anyway - maybe an employee processed a suspicious transaction, maybe your program had a technical deficiency you didnt even know about - prosecutors argue that your documented knowledge proves "willful blindness."
Willful blindness is a legal doctrine that says you dont actualy have to KNOW money was dirty. You just have to have conciously avoided learning the truth when the signs were there. Your compliance program proves you knew what to look for. The fact that you didnt catch something proves you must have been looking the other way.
Its a trap with no exit.
Dont have a compliance program? Thats evidence you didnt take BSA requirements seriously - criminal negligence at minimum, willful violation at maximum.
Have a robust compliance program? Thats evidence you knew exactly what you were supposed to catch - and your failure to catch it proves willful blindness.
There is no compliant path that protects you from prosecution if federal authorities decide your a target.
The Cascade That Destroys Everything
Let me show you what one flagged transaction actualy triggers.
WARNING: This cascade happens automaticaly. You cannot stop it once it starts.
Day 1: A customer makes three deposits totaling $28,000, structured as three transactions under $10,000. Your employee processes them thinking nothing of it.
Day 2-30: Your banks software flags the pattern. A Suspicious Activity Report gets filed with FinCEN. You dont know this happened.
Days 30-90: FinCEN's pattern-matching software identifies the structuring pattern. Your business gets flagged in there database. An alert goes to IRS Criminal Investigation. You still dont know.
Days 90-180: IRS-CI opens a preliminary investigation. They subpoena six months of bank records. They start looking at every transaction in your account. They see patterns everywhere - because cash businesses naturaly have patterns. You still dont know.
Days 180-365: The investigation expands. FBI gets involved becuase money laundering is their jurisdiction too. Grand jury subpoenas go out to your vendors, your employees, your business partners. Someone talks. Multiple someones talk. You might start hearing rumors something is wrong, but you have no confirmation.
Days 365-540: Target letter arrives. You finaly learn you've been under investigation for 18 months. The government has already interviewed a dozen witnesses, analyzed thousands of transactions, and drafted a theory of the case.
Days 540+: Indictment. Charges include structuring (31 USC 5324), money laundering (18 USC 1956), operating an unlicensed money transmitting business, conspiracy. Potential sentence: 10-20 years. Asset forfeiture proceedings begin. Your bank accounts are frozen. Your business is effectivly destroyed before trial even begins.
The average sentence for money laundering is 62 months. Thats over five years in federal prison. No parole in the federal system - you serve 85% minimum.
But the sentence is almost secondary to what happens before trial. Your assets get seized through civil forfeiture. Your bank accounts are frozen. Your business cant operate. Your employees scatter. Your reputation in the community is destroyed. Even if you ultimatley win at trial - which happens less than 10% of the time - your life as you knew it is already over.
This is why federal prosecutors have such high conviction rates. They dont need to convict you. They just need to indict you. The process is the punishment.
And heres whats truly terrifying: this entire cascade started from one customer transaction that you didnt even know was problematic.
What Federal Prosecutors Actually See
When a prosecutor looks at your ATM business, they dont see what you see.
You see years of hard work building a legitmate operation. You see early mornings and late nights. You see a business that serves your community by providing convenient cash access. You see yourself as a small business owner trying to make a living.
They see cash. Lots of it. Moving through your hands every day.
They see transaction patterns that - to an algorithm designed to find money laundering - look identical to the patterns actual money launderers create. They see a business perfectly positioned to launder proceeds from drug trafficking, fraud schemes, and other criminal enterprises.
They see the Firas Isa case. In November 2025, federal prosecutors indicted the founder of Crypto Dispensers - a company that operated cryptocurrency ATMs accross the United States. The charges? Money laundering conspiracy. The allegation? That his "legitimate" ATM business processed transactions for criminals, and that he either knew or should have known the funds were dirty.
He faces 20 years. His company is now reportedly considering a $100 million sale - the business he built is being liquidated while he fights for his freedom.
This is what "legitimate business" looks like to federal prosecutors.
The thing is, prosecutors dont need to prove you actualy knew every customer was a criminal. The willful blindness doctrine means they only need to prove you SHOULD have known. That you saw red flags and looked the other way. That you built a business model that was - intentionaly or not - designed to avoid scrutiny.
They see the Olumide Osunkoya case from the UK. He operated 28 cryptocurrency ATMs without proper registration. When regulators refused his application, he kept operating under a different identity. He processed 2.5 million pounds. He got 4 years in prison.
Prosecutors look at your operation and see the next prosecution. They have quotas. They have career incentives. They have an entire infrastructure built to identify and prosecute ATM operators.
The enforcement trends make this worse every year. Remember that 45% increase in money laundering prosecutions since 2020? Thats not slowing down. The federal government has made financial crimes a priority. Crypto ATMs specificaly are under intense scrutiny becuase theyre seen as the new frontier of money laundering.
If you think your traditional ATM operation is somehow safer then crypto operations, think again. The same transaction monitoring, the same CTR requirements, the same structuring laws apply. The only difference is that crypto prosecutions get more press coverage.
Your operation is generating exactly the same red flags. You just havent been selected for prosecution yet.
The Window You Didnt Know Was Closing
At Spodek Law Group, we have represented ATM operators at every stage of federal investigation. Before target letters. After target letters. Pre-indictment. Post-indictment. Trial. Sentencing.
Heres what we know: the earlier you get legal representation, the more options you have.
If your reading this article, your probably in one of three situations.
First, you might have already recieved a target letter or grand jury subpoena. If so, stop reading and call immediately. You are in active danger and every day without representation is a day the prosecution builds their case while you do nothing. The clock is running.
Second, you might have heard rumors - employees being contacted by investigators, strange questions from your bank, subpoenas going to your business partners. These are warning signs. An investigation is likely already underway. You need representation NOW, before the formal notification arrives.
Third, you might be running an ATM business and wondering if you could be a target. Heres the uncomfortable truth: if your processing significant cash volume, your already generating CTRs and potentially SARs. Your already in the FinCEN database. Your already being analyzed by pattern-matching algorithms.
Maybe you havent done anything wrong. Maybe your compliance is perfect. Maybe every transaction you've ever processed was completley legitimate. It dosent matter. The system is designed to flag patterns, not intentions. And cash businesses - by there very nature - generate the patterns that trigger investigations.
The question isnt whether your being watched. The question is whether the patterns in your business have already triggered an investigation you dont know about.
Every ATM operator thinks there business is different. That there compliance is better. That there operation is too small to attract attention. The median value of laundered funds in federal prosecutions is $200,000. You dont need millions to become a federal target.
The window for pre-emptive action is closing. Or its already closed, and you just dont know it yet.
Federal prosecutors have been building cases for 12-24 months before targets learn anything is wrong. The investigations you dont know about are the ones that destroy you.
They had years to prepare. You have days to respond. Maybe hours.
The asymetry is intentional. Federal prosecutors build cases slowly and carefully, knowing that by the time they reveal themselves, the target has almost no time to mount a meaningful defense. Every day you wait is a day they use against you.
Todd Spodek and the team at Spodek Law Group understand federal money laundering investigations from the inside. We know how FinCEN works. We know how IRS-CI builds cases. We know the pressure points and the opportunities that exist before charges are filed - opportunities that disappear once the indictment drops.
The call costs nothing. Not making it costs everything.
Call Spodek Law Group at 212-300-5196. The next 48 hours may determine the next 20 years of your life. Dont let the investigation you dont know about become the conviction you never saw coming.
