If you receive the ACH credits for ATM transactions at your bank, then I would require them to also fund the ATM with cash from your bank. in addition, I require the ATM ACh credits and cash withdrawals to be made in a separate individual account where only the ATM transactions occur. That is the only way you can monitor the MSB activity and the ATM activity individually and separately to see the flow of funds in regards to each separate type of high risk activity.
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