Previously, our bank matched ATM withdrawals and cash withdrawals for privately owned ATM owners. We have one now that is not matching for multiple months - off by $7,000 - $15,000 for at least 3 months reviewed. I've read that some banks are okay that the business uses their cash store sales to replenish the ATM as well as cash withdrawals? How do you mitigate risks or feel comfortable there is no suspicious activity?

Has the cash that would normally be deposited by the customer into their operating account dropped by a corresponding amount?

I will check that - thank you

They are reviewed twice a year versus annual to see if the activity remains consistent as past volumes. Serves us fine and not audit/exam issues with this process either. Over 50% of our ATM folks self-fund.

An ATM owner that replenishes from cash on hand may require a bit more due diligence either in frequency or the depth of the EDD review. Generally if you are reviewing and see evidence of self replenishment, you would add the cash that they are putting in the machine into their cash deposit totals and evaluate if that makes sense for that specific business.