Originally Posted by
javabytes
The C in CTR stands for currency, which is notably absent from the issuance of an electronic voucher.
If I am a DL lawyer, out of an abundance of caution, you have to ask the question, "what happens if... and what's the risk?" What happen if a customer gets the voucher and is travelling overseas and declares they have a financial instrument over $10K? What happens if that customer that gets the voucher then sells it to drug dealers who are attempting to launder money and in turn they flip it again (they frequently use gift cards to aid in the effort)? Although the gov can argue that DL was trying to skirt rules and should have know a large voucher like this could be used for illicit purposes, by keeping it just under $10K, it is one more added protection that at least minimizes risk.