The act requires any enterprise or person engaged in a trade or business to (without notifying the client) report transactions (or a structured series of related transactions) involving $10,000 or more in U.S. or foreign currency. At minimum, such identification will include the name, address and such other information as the Secretary of the Treasury may require from the provider of the cash, including the source of the information provided and the nature of the transaction. The structuring requirement means that enterprises must report all events that might be attempts to violate the law.
So that damage was done last year.
I'll keep looking - the language could well be buried somewhere.