Other than the Phase 1 exemption in regards to CTR filing, are there any other exemptions in BSA for a bank as a customer?

Specifically in regards to bank cash placed in ATM's. The risk of money laundering is low to non-existent when bank cash is loaded by a 3rd party Armored Carrier into ATMs. How closely does Bank A need to look at Bank B (that has an account at Bank A solely for the purpose of providing cash for ATMs)?

Your entire AML program is risk based. U.S. banks and government entities, now automatically exempt from currency transaction reporting, almost by definition pose no tangible money laundering risk to your institution.

Welcome to BOL.

Thanks Ken. I wish the other banks (and regulators) saw it that way!