The more that some bankers do to pull every possible cash transaction under aggregation, the more the "bar" gets raised for financial institutions generally. When your customer obtains cash at an ATM or via POS cash-back, it's considered just like making a cash withdrawal. To the extent that your system is able to aggregate those cash amounts with other cash withdrawals, you are expected to do so.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8