These are the statues:
31 USC 5324 - The Structuring Statute:
http://www.law.cornell.edu/uscode/text/31/5325
31 USC 5325 - Identification Statute:
http://www.law.cornell.edu/uscode/text/31/5325
Andy I see what you are talking about. When reading 5324 alone it seems that "Domestic Coin and Currency Transactions" Refers only to cash but read it in conjunction with 5325.
"No financial institution may issue or sell a bank check, cashier’s check, traveler’s check, or money order to any individual in connection with a transaction or group of such contemporaneous transactions which involves United States coins or currency"
Does United States coins or currency mean physical cash or does it mean the money order is drawn in US Dollars and not a foreign currency? I don't know but my reading is that this *could* apply to a debit card transaction if you take a broad view.
If 5325 applies to a debit card my reading of the requirement that "No person shall, for the purpose of evading the reporting requirements" seems to insulate MSers because that is not the intent.
However when there are discussions about when ID is required and where to go to avoid giving it in addition to huge deposits at ATMs I'm not so sure the government could not argue that MSers are attempting to avoid reporting requirements.
I'm not accusing anyone of doing anything wrong but there seems to be an attitude that all MS techniques are 100% legal. My only point with this post is that there are so many federal crimes and IRS regulations I don't know that anyone can say with complete certainly they are complying with all of them. Everyone has their own comfort zone and to each their own.