If you have any customers with "private" ATMs your BSA-AML program should address the issue. However, this is a horse of a different color; this is not the risk you agreed to take. A Bitcoin ATM is not a simple cash dispenser and your risk mitigants simply will not work here. Banking these people, particularly a business that allows large cash deposits made by an unconnected third party, would indicate an enormous appetite for risk on the part of your bank.
Last edited by Elwood P. Dowd; 10/02/18 11:33 AM. Reason: Rewritten
You need to have a sit down with your customer and begin to move on eliminating the problem.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.