How to Fill Out FinCEN Form 105: Filing, Penalties, and Structuring

If you’re moving more than $10,000 in cash or cash-like instruments into or out of the United States, here is how to fill out FinCEN Form 105: identify yourself in Part I, name the owner of the funds in Part II if the money isn’t yours, enter your travel details in Part III, itemize every bill and instrument in Part IV, and sign Part V. You can submit it online at fincen105.cbp.dhs.gov, hand a paper copy to a CBP officer at the border, or mail it in before a shipment leaves.¹

The form’s full name is the Report of International Transportation of Currency or Monetary Instruments. It exists because the Bank Secrecy Act requires Treasury to track large physical movements of money across U.S. borders. Filing itself is free, legal, and creates no tax liability. What creates problems is skipping it, lying on it, or splitting the money to avoid it.

Before You Start: What Counts Toward $10,000

The threshold covers more than paper bills. Federal regulations define “monetary instruments” to include several categories, and you must add them all together:²

Coins and paper money of any country, U.S. or foreign.
Traveler’s checks in any form.
Negotiable instruments in bearer form: personal checks, business checks, cashier’s checks, promissory notes, and money orders that are payable to bearer, endorsed without restriction, or made out to a fictitious payee.
Signed instruments with the payee line left blank.
Bearer securities, where ownership transfers by handing over the physical document.

Warehouse receipts and bills of lading are excluded.² Wire transfers and other electronic movements through the banking system are also excluded, because they don’t involve physically moving cash.³

For foreign currency, convert to U.S. dollars using Treasury’s official exchange rates, which are the federal standard for dollar-equivalent reporting.⁴ Carrying multiple currencies? Each one gets listed separately on the form and totaled in dollars.

Gold coins are a narrow case. A coin qualifies as “currency” only if it is designated legal tender, actually circulates, and is customarily used as a medium of exchange in its issuing country. FinCEN won’t rule on individual coin types, so you apply the test yourself. Gold bullion bars that aren’t legal tender anywhere don’t count as monetary instruments, though they may trigger other customs requirements.⁵

One more thing before you fill anything out. The obligation to file isn’t limited to the person physically holding the money. If you arranged for someone else to carry, mail, or ship funds for you, you’ve “caused” the transportation and you’re on the hook too. Same if you receive a shipment of more than $10,000 in the U.S. from abroad and no report was filed.³ And “closely related events” can be aggregated. You can’t hand $6,000 to your spouse and carry $5,000 yourself and call it two events under the threshold.⁶

Part I: Your Personal Information

Part I identifies the person physically transporting, mailing, or receiving the funds. Enter your full legal name, permanent address, and date of birth. You’ll need an identification number: your Social Security number if you have one, or your passport number or alien registration number if you’re a foreign national without an SSN. Then enter your passport number and its issuing country.⁷

Part II: If the Money Belongs to Someone Else

Skip Part II if you’re carrying your own money. Fill it in if you’re carrying funds for another person or for a business. List the owner’s full name (or business name), permanent address, and their occupation or type of business. The form asks specifically whether the business is a bank. “Person” here includes corporations, partnerships, trusts, and other legal entities, so this section applies any time the money isn’t yours.⁷

Part III: Travel Details

Part III has two sections. Fill out A or B, not both.

Section A is for exports (money leaving the U.S.). Enter the U.S. port city you departed from and the foreign city and country you’re headed to.

Section B is for imports (money entering the U.S.). Enter the foreign departure city and country and the U.S. city where you’re arriving.

Either way, include the airline and flight number, or the vessel name if you’re arriving by sea.⁷

Part IV: The Money Itself

This is the itemization section. Break the funds into two categories.

Coins and paper currency go on one line as a single total. If any of it is foreign currency, note the currency name and country of origin. Carrying more than one foreign currency? Attach a separate list showing each type, its country, and its amount, then bring the U.S. dollar total onto the form.

Other monetary instruments get listed individually. For each traveler’s check, cashier’s check, money order, or bearer instrument, enter the type, the issuing entity, the date, and the serial or identifying number. Total that category separately, then add the two totals together for the grand total.⁷

Accuracy matters here. If a CBP officer counts your cash and it exceeds what you wrote down, you have filed a report with a material misstatement.

Part V: Signature

Sign and date the form. Your signature certifies that everything above is true and complete. The certification is tied to the reporting requirements under 31 U.S.C. 5316, and a material misstatement can trigger both civil and criminal penalties.⁶

How to Submit the Form

You have three options, and which one you use depends on how the money is moving.

Online. CBP recommends electronic filing as the fastest route. Submit through fincen105.cbp.dhs.gov before or during your trip. Travelers using Mobile Passport Control for U.S. entry can also access the electronic form through that process.¹

In person. If you’re carrying the money yourself, complete a paper form and hand it to a CBP officer at your port of entry or departure. Print it from FinCEN’s website in advance or ask an officer for a copy. Expect the officer to inspect and count your funds to verify the amount you reported.⁷

By mail (for shipped or mailed currency). When the money is being shipped or mailed rather than hand-carried, file Form 105 by mail on or before the date of shipping, mailing, entry, or departure. Send it to: Attn: OIT/CBP/CMIR, Passenger Systems Directorate, 22001 Loudoun County Parkway, Mail Stop 1258, Ashburn, VA 20598. Filing after the shipment has already moved puts you in violation.⁷

Don’t Split the Money to Avoid Filing

Breaking a large sum into smaller amounts to stay under $10,000 is called structuring, and it’s a separate federal crime under 31 U.S.C. 5324. You don’t have to succeed for the law to apply; the attempt is enough. Structuring an import or export of monetary instruments carries up to five years in prison and fines up to $250,000. If it’s part of a pattern of illegal activity exceeding $100,000 in a 12-month period, the maximum doubles to ten years and $500,000.⁸

Carrying $15,000 and reporting it is legal. Splitting the same $15,000 across two trips to duck the report is a felony.

Penalties for Not Filing or Filing Falsely

Getting Form 105 wrong, or skipping it entirely, exposes you to three separate consequences.

Civil penalties can reach the full value of the monetary instruments involved. Fail to report $25,000, and the government can impose a civil penalty of up to $25,000, reduced by anything already forfeited through seizure.⁹

Criminal penalties apply when the violation is willful. A standard conviction carries up to five years in prison and a fine of up to $250,000. When the violation accompanies another federal crime or is part of a pattern of illegal activity exceeding $100,000 in a 12-month period, the maximum rises to ten years and $500,000.¹⁰

Forfeiture is the harshest layer. CBP officers can search any person, vehicle, or container at the border without a warrant to check for unreported monetary instruments. A court can then order forfeiture of all property involved in the violation, either at criminal sentencing or through a separate civil forfeiture action.¹¹

Filing the form takes a few minutes and costs nothing. Skipping it can cost you the cash, a quarter-million-dollar fine, and up to five years in federal prison.

1
U.S. Customs and Border Protection. Money and Other Monetary Instruments
2
eCFR. 31 CFR 1010.100 – General Definitions
3
eCFR. 31 CFR 1010.340 – Reports of Transportation of Currency or Monetary Instruments
4
U.S. Treasury Fiscal Data. Currency Exchange Rates Converter
5
Financial Crimes Enforcement Network. FinCEN Form 105 – Currency and Other Monetary Instruments Report
6
Office of the Law Revision Counsel. 31 USC 5316 – Reports on Exporting and Importing Monetary Instruments
7
Financial Crimes Enforcement Network. FinCEN Form 105 – Report of International Transportation of Currency or Monetary Instruments
8
Office of the Law Revision Counsel. 31 US Code 5324 – Structuring Transactions to Evade Reporting Requirement Prohibited
9
Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
10
Office of the Law Revision Counsel. 31 USC 5322 – Criminal Penalties
11
Office of the Law Revision Counsel. 31 USC 5317 – Search and Forfeiture of Monetary Instruments