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1356. Bank Robbery -- Bank Messenger -- Armored Truck Services

In addition to thefts and robberies committed on bank premises, the Federal bank robbery statute also may encompass thefts and robberies of bank messengers and armored truck services. The key factor in determining whether a violation of 18 U.S.C. § 2113 has occurred in such circumstances is whether or not the stolen money belonged to or was in the care, custody, control, management, or possession of a federally protected financial institution. See United States v. Marzano, 537 F.2d 257 (7th Cir. 1976), cert. denied, 429 U.S. 1038 (1977).

Cases in this category also may involve violations of 18 U.S.C. §  659 if the money or other property taken constituted an interstate or foreign shipment which had not reached its destination. Accordingly, the investigation should encompass not only the facts surrounding the robbery, but should ascertain the contractual relationship between the bank and the messenger service and the duties and functions of such service, particularly with reference to the money or other property taken.

[cited in USAM 9-61.600]

Updated June 9, 2015