Pretty simple. Cash placed from the til into the ATM is cash that you do not see deposited so you need to have a way to identify the ACH settlement from the ATM and include that in your EDD analysis when trying to determine if the volume of cash the business generates is reasonable. This can be a challenging and time consuming process if the transactions are comingled in an operating account.
The bank is well within its rights to require that the customer open a separate ATM account the receives ACH settlement and then require that the machine be filled with cash withdrawals from the account. The reduces the risk of a customer filling the ATM with "alternative" sources of cash that could be derived from illegal activity.
If you are banking an MSB that cashes checks put "promises" not to cash checks over $1,000 you also inherent the fun task of periodically monitoring deposited checks to make sure that they are adhering to that. For me, I'd rather have them registered with FinCEN as a check casher and review their BSA Program. Otherwise I'm running the risk of having to file a SAR for an unregistered MSB if they routinely "forget" the $1,000 limit.
Filing CTRs regularly does not mean that there isn't suspicious activity. Don't fall into that trap. Some of the best fraud is done out in the open because the fraudsters figure no one will question since "Who would commit fraud in broad daylight?" and then we let our guard down which is what they are counting on.
Due diligence should include comparing anticipated to actual activity, comparing volume of activity from one period to the next and to similar periods from the previous year looking for unexplained changes in behavior. It may require reviewing financials to see if the volume of activity is similar to reported annual sales. Ultimately you have to keep collecting information like pieces to a puzzle until you understand what the picture is supposed to be.
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