It's a spreadng practice. Australia is introducing (or may have already passed?) a similar Act with an AU $10K limit on "unapproved" cash transactions. Over the limit you'll need approval. Of course the usual loophole for the weathy applies, 3x $3,000 face value gold bullion coins [1] is under the cash transaction limit, although at a kilo each and ~$88K per in valuae, that's almost $300K in value technically under a…
If you use it to pay $88k then the transaction is obviously $88k although you've then paid in gold, not cash.
I feel that this is a "you can't have your cake and eat it too" situation.