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sorted banks into four tiers. Beyond the critical group, it Once compromised, the ATM can be forced to dispense its
identifies a “stressed” tier of 223 banks that would remain cash reserves without requiring legitimate transactions or
profitable but could face earnings pressure, potentially PIN verification. The FBI noted that because the malware
tightening underwriting or reducing appetite for revolv- attacks the ATM itself rather than individual accounts, the
ing credit. Some institutions, the report noted, were al- cash-out process can occur in minutes and often goes un-
ready unprofitable before applying the cap. detected until after the money is gone.
Amberoon warned that ripple effects could be materially Recent law enforcement actions highlighted the scope
significant if specialist issuers responded by shrinking of the problem. For example, in February 2026, a federal
lines, closing accounts or moving upmarket—affecting grand jury in Nebraska indicted six individuals in connec-
consumers and small businesses that use cards as backup tion with jackpotting attacks. The charges followed a De-
liquidity. It also anticipated demand shifting to BNPL or cember 2025 indictment alleging that the foreign criminal
other alternatives. Conversely, the report argues retrench- group Tren de Aragua orchestrated similar attacks nation-
ment by large issuers could open opportunities for com- wide, involving 22 defendants.
munity banks to expand installment lending.
The FBI recommends several defensive measures for fi-
Jackpotting siphons millions of dollars off ATMs nancial institutions, including replacing standard ATM

ATM jackpotting attacks are increasing sharply across the locks, installing alarm-triggering keypads on mainte-
United States, costing financial institutions millions of nance panels, encrypting hard drives, expanding camera
dollars and prompting new warnings from federal author- coverage and regularly auditing machines.
ities. According to a recently released FBI bulletin, more New York sets BNPL regs into motion
than 1,900 jackpotting incidents have been reported since
2020. Over 700 of those occurred in 2025 alone, resulting in New York is moving to establish one of the nation’s most
losses exceeding $20 million. comprehensive regulatory frameworks for buy now, pay
later (BNPL) financing, with rules proposed Feb. 24, 2026,
Jackpotting refers to a form of ATM fraud in which crimi- to implement legislation signed by Governor Kathy Ho-
nals manipulate machines to dispense their stored cash, chul in January.
much like a slot machine paying out a jackpot. Attackers
often combine physical tampering with malware designed The proposed regulations would apply to both interest-
to seize control of the ATM’s operating system. free BNPL products and installment loans that carry inter-
est or finance charges. If adopted, the rules would require
One common tool used in these attacks is malware known BNPL providers operating in New York to obtain licenses
as Ploutus, which targets the Windows operating systems and submit to state supervision. They would also prohibit
that power many ATMs. Criminals typically gain access to excessive or “junk” fees, limit late and penalty charges,
a machine using generic keys that can open an ATM’s front and require companies to clearly disclose whether loans
panel. Once inside, they may remove the hard drive and will be reported to credit bureaus. Additional provisions
install malware before reinstalling it or replace the drive would set standards for resolving consumer disputes and
entirely with one already loaded with malicious software. establish protections against misuse of consumer data.

State officials said the rules aim to ensure that innova-
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can’t miss events and newest
ind us t r y a nno unc e me n ts. oversight while ensuring transparent loan terms and fair
industry announcements.
dispute processes.
Consumer advocates believe the New York framework
could become a model for lawmakers nationwide seeking
to address growing risks associated with BNPL use. Lau-
ren Saunders of the National Consumer Law Center said
many BNPL borrowers have subprime credit profiles and
already carry significant debt, making stronger oversight
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