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.
You need to have a sit down with your customer and begin to move on eliminating the problem.
Last edited by Elwood P. Dowd; 10/02/18 11:33 AM. Reason: Rewritten
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.