Currency Export Rules Review

The Treasury’s Financial Crimes Enforcement Network (FinCEN) has published a Federal Register notice reaffirming existing rules requiring individuals and certain entities to file Form 105—the Report of International Transportation of Currency or Monetary Instruments (CMIR)—for physical transfers exceeding $10,000 entering or leaving the United States.

Witten comments must bereceived within 60 days of the notice's June 18, 2025 publication in the Federal Register.

In fiscal 2023, there were approximately 143,200 CMIR filings—part of a broader enforcement framework alongside 20.8 million Currency Transaction Reports (CTRs) and 4.6 million Suspicious Activity Reports (SARs)

A June 2024 GAO report criticized the surge in BSA filings—including CTRs—highlighting ballooning volume, a fixed $10,000 threshold untouched since 1972, and that law enforcement accessed just 5.4% of CTRs from 2014–2023, suggesting many reports go unused. The GAO urged FinCEN to simplify forms, clarify aggregation rules, eliminate seldom-used fields, and possibly raise reporting thresholds.

In March 2025, the Independent Community Bankers of America endorsed a proposal (H.R. 1799) to raise the CTR threshold to $30,000 and index it to inflation—citing excessive compliance costs on community banks.

A FinCEN alert issued in June 2025 emphasized that CMIR filings are critical to anti‐money-laundering (AML) investigations, especially in probing bulk cash smuggling and trade‑based laundering networks

This FR Doc. 2025‑11211, reiterates longstanding and unchanged CMIR obligations.

Reports of Transportation of Currency or Monetary Instruments; Report of International Transportation of Currency or Monetary Instruments