For wire transfers recordkeeping requirements, the BSA/AML Examination manual states the following:
For each payment order in the amount of $3,000 or more that a bank accepts as an originator's bank, the bank must obtain and retain the following records.

I know this may be a silly question but when it states '$3,000 or more', is it referring that the currency transaction amount for each payment order has to be $3,000 or more for the recordkeeping? For example, if a customer A's payment order is only $1,000 but A deposits $3,000 in currency for this wire transfer and other expense. Then we have to keep a record of this payment order. A few people at my work think this is how the recordkeeping should be done. However I think $3,000 or more rule refers to only the payment order amount specified by the customer regardless of the any currency transaction amount. Who's right? Am I wrong?

Thank you in advance.

The amount of currency involved is relevant to record retention for official checks. The presence/absence of currency is not relevant to record retention on funds transfers.

If it's $3,000 or more you keep what you're told to keep.

That's what I thought. Thank you!