What exactly does FinCEN Form 105 require and how do travelers complete it at U.S. ports of entry?

1. What triggers the duty to file: the $10,000 threshold and what counts as “currency or other monetary instruments”

The statutory trigger is the physical transportation, mailing, or shipping of currency or “other monetary instruments” in an aggregate amount exceeding $10,000 at one time into or out of the United States, as required by the Bank Secrecy Act and implementing CMIR rules ^{[1] [3]}. “Currency and other monetary instruments” include paper and coin (U.S. and foreign), travelers’ checks, certain bearer negotiable instruments, incomplete instruments that can be completed to bearer, and bearer securities; items like personal checks to a named payee or most debit/credit cards and purely electronic wire transfers are typically excluded from CMIR reporting ^{[5] [1]}.

2. Who must file and when: travelers, recipients, shippers, and common carriers

People carrying reportable amounts while entering or departing the U.S. must file at the time of entry or departure with the Customs officer in charge at the relevant port—or use the electronic filing option—while recipients of funds already transported into the U.S. must file within 15 days after receipt if no prior complete report exists ^{[2] [3] [4]}. Common carriers and armored carriers that physically move currency are also subject to filing requirements, although guidance says a carrier may be excused if another party files a truthful, correct, and complete report ^[6].

3. How travelers actually complete the form at ports of entry and departure

Travelers can obtain a paper Form 105 from CBP offices at ports or print it beforehand, but FinCEN and CBP recommend electronic filing through the FinCEN Form 105 website as the fastest method; alternatively the completed paper form is presented to a CBP officer upon arrival or prior to departure ^{[2] [7]}. The form collects identifying information (name, address, travel details), a description and amount of the currency/monetary instruments, and information about who acted in transporting the funds; those acting for others must complete an additional section ^{[3] [6]}.

4. Special procedural notes: departures, mailings, and Mobile Passport Control

Practical logistics vary: when funds do not accompany a person (e.g., mailed or shipped), shippers may file by mail on or before the date of entry or departure using the address specified by CBP/FinCEN; travelers using Mobile Passport Control may integrate the declaration electronically into arrival procedures where available ^{[3] [8]}. FinCEN guidance for common carriers details specific completion rules—such as specifying the U.S. origin port and ultimate foreign destination on outbound reports—to reduce processing delays ^[6].

5. Consequences, accuracy, and enforcement risks

Failure to file a CMIR, filing a materially false report, or attempting to structure movements to evade reporting carries civil and criminal penalties under the BSA; FinCEN and CBP expect truthful, complete reporting and emphasize that one party’s filing can relieve others only if it is correct and covers the transportation ^{[3] [8] [6]}. Legal-advice sources and customs attorneys repeatedly warn that inaccuracies or omissions can lead to seizures, fines, and further scrutiny ^{[4] [9]}.

6. Where coverage is thin and what travelers should confirm before relying on this summary

Public guidance explains the core rules and how to file, but real-world airport procedures—such as where to hand a paper 105 during a busy international departure, how CBP integrates MPC at every port, or how specific airlines direct passengers—are handled locally and can vary; those operational details are not exhaustively documented in the FinCEN/CBP materials cited here and may require contacting the port’s CBP office or checking the FinCEN filing portal ^{[2] [7] [10]}.