I will have to think about whether this is an all-inclusive rule. I'll stipulate to an exception, since there is always at least one. But yes, we almost always use two atemis in Kote Gaeshi. When we intercept an attack*, we backfist to the face (I prefer the pie-in-the-face, personally), then again right before we execute the throw. This keeps a hostile uke from punching us after the return, or pivot. Also, it gives us a moment to make sure we have the kote.
*For most ichi techniques, Shite initiates with an atemi.
Got it, you are counting shomenuchi dai ichi as an atemi.
Quick question before we get too 'in the weeds.' For (kihon waza) Shomenuchi Kotegaeshi dai ni, are you initiating with a front strike to uke before your pivot shift, or are you pivoting and blending with uke's strike as you make your initial pivot shift? I just looked at some clips online and I'm seeing some variances. The second part of the technique all looks congruent; the slide out, pivot, atemi, pivot, throw...I just mean the first part (of #2).