What due dilligence do most of you do with customers that own/lease ATM's and do you also do a site visit? Thanks!

I compare their cash out withdrawals for stocking the ATM to their incoming credits from their ATM service company on a quarterly basis to make sure they are fairly close. I document the total monthly transactions (pertaining to ATM) credits/debits on a spreadsheet to show examiners. I also do a site visit to confirm the existence of the ATM. We just had an exam and the examiners seemed fine with this approach.

FYI I would also be reluctant to provide cash to a customer with an ATM if they are involved in a substantial amount of ineligible business activities as defined in 31 CFR 103.22(d)(6)(viii). If they are selling a few lotto tickets I would be okay with that but not if any ineligible activities are a big part of their business. While there is no prohibition on banking someone with these activities I would not be comfortable providing them with lots of cash on a regular basis. Just my preference.