Crossing Borders With Cash? FinCEN Renews the Form 105 Paperwork
Published Date: 6/18/2025
Notice
Summary
If you carry or send more than $10,000 in cash or money instruments across U.S. borders, you need to file a special report called FinCEN Form 105. The government is renewing this rule without any changes and wants your feedback by August 18, 2025. This keeps things clear and helps stop illegal money moves without adding extra paperwork or costs.
Analyzed Economic Effects
7 provisions identified: 2 benefits, 5 costs, 0 mixed.
You remain liable if a truthful CMIR was not filed
The rule clarifies that no person required to file a CMIR is excused from liability for failing to file if, in fact, a complete and truthful report has not been filed. That legal liability remains in place for required filers.
File a FinCEN Form 105 if you cross $10,000
If you physically carry, mail, ship, cause, or attempt to move currency or other monetary instruments totaling more than $10,000 at one time into or out of the United States, you must file a Report of International Transportation of Currency or Monetary Instruments (FinCEN Form 105 / CMIR). This rule applies to individuals and entities and is based on the statutory $10,000 threshold.
When and how quickly to file CMIRs
CMIRs for currency that accompanies a person must be filed at the time of entry into or departure from the United States. For currency or monetary instruments not physically accompanying a person, or for receipts in the U.S., the CMIR must be filed by mail or otherwise on or before the date of entry, departure, mailing, or shipping, or within 15 calendar days after receipt if you received the funds in the U.S.
Certain banks and transport businesses are exempt
Some persons are not required to file a CMIR. Exemptions include banks and foreign banks, brokers or dealers in securities for currency mailed or shipped through the postal service or by common carrier, and persons engaged in the business transportation of currency overland between established bank or broker offices. Also, transfers made through normal banking procedures (not physical transport of currency) are not reportable on the CMIR.
You can file CMIRs electronically or on paper
You may obtain and complete CMIRs in paper form from Customs and Border Protection (CBP) or FinCEN, or complete the CMIR electronically via CBP's web-based platform or other internet-capable devices such as a smartphone. Travelers who use the electronic platform must present evidence of electronic completion to the CBP officer at the port of entry or departure.
Paperwork burden and cost estimates for CMIRs
FinCEN estimates about 108,400 unique annual respondents and approximately 140,687 required CMIR reports per year, with an average completion time of 17.95 minutes per report. The agency estimates an average cost per response of $15.99, total annual burden hours of 42,089, and total annual cost of $2,250,492.
Extra information required when you file for someone else
If you transport, ship, mail, or receive currency or monetary instruments on your own behalf, you must provide your own information on the CMIR. If you act for another person, you must provide your own information and information about the person or business on whose behalf the activity was conducted; if currency is mailed, you must also include sender and/or recipient information as instructed.
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2026-20429, Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal
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2026-20371, Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network's Sub-Agents
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