As part of our enhanced customer due diligence on privately owned ATMs, we are requesting the confirmation from the state of OK that they have filed. It is also required to be renewed annually, so we request that too.
As for monitoring for AML, there are several resources that provide red flags to watch for on privately owned ATM accounts. Primarily, you want to know how they are funding the ATM. If they are using their own funds from a source other than their bank account, there is a good chance that money laundering could occur. Also compare the ATM cash outs with the ACH credits, for the same reason.
Hope that helps!
It is actually possible for you and I to have different opinions and yet still live peaceably upon this planet.