Don't take any of these suggestions above as "gospel" since each fact situation is different. For instance, you need to know whether a customer's revenue comes primarily from the operation of the ATMs or if this is just a sideline income. That will enter into a discussion of whether the customer might be exemptible (although I would not favor exempting a non-bank ATM operator).
In other words, you probably need to discuss your specific situation with a FinCEN representative or your own regulator. Try to get a response in writing. If you can't, get the representative's name and address, and write that person a detailed description of the telephone conversation and findings, to document what you heard.
I would be interested in figuring out how an ATM operator might be considered a money transmitter, Tink. Or was your issue not about an ATM operator?
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8