The point I am making is they are talking about structuring (breaking laws) as it relates to gift cards. They have no idea what the limits are as it relates to gift cards. What reporting are they required to do under federal law for gift card purchases?
They never claimed they know the limits or reporting requirements in cases of gift card structuring. As they write pretty clearly:
"Splitting up the purchase of prepaid cards into multiple transactions
may constitute structuring.
It is strictly against the law for customers to structure transactions
to avoid the record keeping or reporting requirements required by law.
It is against CVS/pharmacy policy for customers to structure transactions to avoid CVS/pharmacy prescribed limits on money services products."
They only say that structuring GC purchases
may be against the law, and that it is against the law to structure
if there is a reporting requirement (which I'm not sure sure if there is, and it seems they're unsure of the same). Now, even if structuring for GCs is legal, corporate policy forbids it.
The memo should address CVS policy and not some imaginary law that is being broke.
It does, as quoted above.
