Do withdrawals at foreign ATMs (not our bank's ATMs), count against the customer for Reg D purposes or are those withdrawals considered in person?
Withdrawals made at an ATM are not counted against the customer for Reg D purposes. I don't believe there is any distinction in the regulation as to whether or not the ATM is the bank's or a foreign ATM.
Whether the ATM is at your bank or in Istanbul, those withdrawals don't need to be counted.