FinCEN 105: Currency and Monetary Instrument Reports (CMIR)

Key Points

• FinCEN 105 is FinCEN Form 105, Report of International Transportation of Currency or Monetary Instruments (CMIR), filed with CBP when currency or monetary instruments are carried, shipped or mailed into or out of the United States.
• The report is required when the aggregate amount exceeds the $10,000 threshold, and the duty to file rests on the traveler, shipper, mailer or recipient, not on CBP.
• FinCEN 105 is not a customs entry form: when a client ships currency, negotiable instruments or bearer securities as cargo, the CMIR is required in addition to any entry filing.
• The governing authorities are 31 U.S.C. 5316 and 31 CFR 1010.340; consequences of failing to report include seizure and forfeiture of the funds plus civil or criminal penalties.
• As of October 2026, the form may be presented on paper to the CBP officer at the port or completed through the FinCEN online form; confirm the current filing channel with CBP before relying on either.

On this page

1. What FinCEN 105 is
2. At a glance
3. Who must file FinCEN 105 and when
4. What counts toward the $10,000 threshold
5. How FinCEN 105 is filed with CBP
6. Where FinCEN 105 fits in a broker's cargo workflow
7. Common FinCEN 105 errors and what they cost
8. Frequently asked questions
9. What importers and brokers should do
10. Key references

FinCEN 105 is FinCEN Form 105, the Report of International Transportation of Currency or Monetary Instruments, commonly called the CMIR. It is filed with CBP by the traveler, shipper, mailer or recipient whenever currency or monetary instruments above the reporting threshold physically move into or out of the United States, and it sits entirely outside the entry process: it reports the movement of money, not the importation of merchandise. The links in this article go to the primary documents, the statute, the regulation and the official agency pages themselves. Read the source.

At a glance

• Full name: FinCEN Form 105, Report of International Transportation of Currency or Monetary Instruments (CMIR).
• Who prepares or uses it: the traveler carrying the funds, or the shipper, mailer or recipient of currency or monetary instruments moving across the border; brokers encounter it when a client ships such instruments as cargo.
• When in the lifecycle: at the time of entry into or departure from the United States, or at the time the instruments are received if they arrived by shipment or mail.
• System or channel: paper form presented to the CBP officer at the port, or the FinCEN online form; confirm the current channel with CBP.
• Governing authority: 31 U.S.C. 5316 and 31 CFR 1010.340.
• Threshold: aggregate amounts over $10,000.
• Related terms: CBP Form 7501, CBP Form 5955A, CBP Form 4647, CBP Form 6084, CBP Form 400, CBP Form 3124, CBP Form 5291, CBP Form 3347, CBP Form 3499, CBP Form 3495.

Who must file FinCEN 105 and when?

FinCEN 105 is filed by the person who physically moves the money or who receives it, which in practice means one of four parties: the traveler who carries currency or monetary instruments across the border, the shipper who sends them abroad, the mailer who posts them, or the recipient in the United States who takes delivery of instruments that arrived from outside the country. A traveler files at the time of entry or departure, with the CBP officer at the port. A recipient files when the instruments are received, which is a trap for companies that assume someone upstream already handled it.

The obligation to file FinCEN 105 is personal to those parties and does not transfer to a customs broker, a forwarder or a carrier simply because that party handled the paperwork. A broker can prepare and present the form as an accommodation, and often should when the client is unfamiliar with the requirement, but the legal duty under 31 U.S.C. 5316 stays with the person transporting, shipping, mailing or receiving the funds.

What counts toward the $10,000 threshold on FinCEN 105?

FinCEN 105 is triggered by an aggregate amount over $10,000, and the word aggregate does real work. The threshold is not measured per bundle, per envelope or per traveling companion. Currency is only the starting point: monetary instruments as defined in 31 CFR 1010.340 reach well beyond cash, and the frequent compliance failure is treating the form as a cash report. Negotiable instruments in bearer form and bearer securities move money just as effectively as banknotes and are reportable on the same basis.

When the exact treatment of a particular instrument is unclear, read the definition in the regulation rather than relying on memory, and confirm with CBP at the port of departure or arrival before the movement happens. The cost of asking is nothing; the cost of guessing wrong can be loss of the funds.

How is FinCEN 105 filed with CBP?

FinCEN 105 is filed with CBP, not with a bank and not through ACE. A traveler presents the completed paper form to the CBP officer at the port on entry or departure, or completes the FinCEN online form; confirm with CBP which channel the specific port expects, because practice differs by location and by mode. For shipped or mailed instruments, the shipper files in connection with the outbound movement and the recipient files on receipt.

Nothing about the FinCEN 105 filing substitutes for the commercial customs paperwork. The CMIR does not release cargo, does not declare classification or value, and is not the entry summary. CBP Form 7501, Entry Summary, the declaration of classification, value, origin, duties, taxes and fees for an entry, filed in ACE within 10 working days of release or with the entry, remains the document every bill, refund and audit traces back to. FinCEN 105 lives beside it, in a separate currency reporting regime.

Where does FinCEN 105 fit in a broker's cargo workflow?

FinCEN 105 enters a broker's world when a client ships currency, negotiable instruments or bearer securities as cargo, because that shipment needs the CMIR in addition to whatever entry or export filing applies. Treat the question as a standing screening step for any client in banking, precious metals, money services or cross border logistics for financial institutions.

Authority matters here. CBP Form 5291, Power of Attorney, the optional CBP format for the written authority an importer gives a licensed customs broker or an employee to transact customs business in its name, lets the broker act on entry matters, but it does not make the broker the reporting person on FinCEN 105. Similarly, CBP Form 3347, Declaration of Owner for Merchandise Obtained Otherwise Than in Pursuance of a Purchase, and its companion 3347A, the Declaration of Consignee When Entry Is Made by an Agent, move duty liability on an entry; they say nothing about currency reporting. Only a person who holds a license obtained through CBP Form 3124, Application for Customs Broker License, the application an individual, partnership, association or corporation files with CBP under 19 CFR part 111, may transact customs business, and even that license does not shift the FinCEN 105 duty off the client.

Other handling forms sit nearby but address merchandise rather than money. CBP Form 3499, Application and Approval to Manipulate, Examine, Sample or Transfer Goods, is the permit request for handling merchandise still under CBP custody in a bonded warehouse, a container station or before release. CBP Form 3495, Application for Exportation of Articles Under Special Bond, is the notice an importer files before exporting goods admitted under a temporary importation bond so CBP can supervise or waive supervision of the export and the bond can be cancelled. Neither replaces a CMIR when the cargo itself is monetary instruments.

Common FinCEN 105 errors and what they cost

The three recurring FinCEN 105 failures are structuring, scope error and timing. Structuring means splitting amounts across people, parcels or days so that no single movement crosses the threshold; it is treated as an attempt to evade the reporting requirement rather than as clever planning. Scope error means reporting cash and omitting the other monetary instruments. Timing error means filing late or not at all, including the recipient who never files because the shipper abroad said it was taken care of.

The consequences attach to the funds and to the people. Failure to report can lead to seizure and forfeiture of the currency or instruments and to civil or criminal penalties. That is a different track from the ordinary customs money forms a compliance team sees: CBP Form 5955A, Notice of Penalty or Liquidated Damages Incurred and Demand for Payment, the Fines, Penalties and Forfeitures notice claiming a penalty or bond liquidated damages, and CBP Form 6084, CBP's bill form for supplemental duties, taxes, fees and interest after liquidation or a rejected payment, both of which arrive on the merchandise side of the house. For context on those, see our notes on CBP Form 5955A and CBP Form 6084.

Frequently asked questions

Is FinCEN 105 a customs entry document?

No. FinCEN 105 is a currency and monetary instrument report filed with CBP, not a customs entry form. It does not classify merchandise, does not calculate duty and does not secure release of cargo; a shipment of monetary instruments may require both a FinCEN 105 and the applicable entry filing.

Does a broker file FinCEN 105 for the client?

A broker may prepare and present FinCEN 105, but the reporting duty under 31 U.S.C. 5316 belongs to the traveler, shipper, mailer or recipient. Brokers should document in writing who is filing the FinCEN 105 and when, rather than assuming the client understands the requirement.

What happens if FinCEN 105 is not filed?

If FinCEN 105 is required and not filed, or is filed with false or incomplete information, the currency or monetary instruments can be seized and forfeited and civil or criminal penalties can follow. Structuring amounts to stay under the $10,000 threshold does not avoid the exposure.

Does paying duties electronically change the FinCEN 105 obligation?

No. Enrolling in CBP Form 400, ACH Debit Application, which signs a payer up for CBP's Automated Clearinghouse debit program to pay duties, taxes, fees and bills electronically, affects only how money is paid to CBP. It has no bearing on whether a FinCEN 105 is due on physical movement of currency or monetary instruments. See our overview of CBP Form 400.

Is FinCEN 105 related to country of origin marking notices?

No. CBP Form 4647, Notice to Mark and/or Redeliver, is CBP's notice that articles or containers are not marked with country of origin, ordering marking, redelivery, export or destruction under 19 CFR 134.51. FinCEN 105 concerns the cross border movement of money and has no marking component.

What importers and brokers should do

• Add a screening question to client onboarding and to shipment intake: does this movement include currency, negotiable instruments in bearer form or bearer securities, and does the aggregate exceed $10,000.
• Read the definition of monetary instruments in 31 CFR 1010.340 and the reporting duty in 31 U.S.C. 5316 directly, and confirm the current FinCEN 105 filing channel and port practice with CBP before the movement.
• Record in the file who the reporting person is for each FinCEN 105, when the report was presented, and to which CBP officer or through which online submission.
• Train staff that no instruction to divide a shipment or a traveling party to stay under the threshold may be followed, and escalate any such request internally.

Key references

• 31 U.S.C. 5316: the statute requiring reports on exporting and importing monetary instruments.
• 31 CFR 1010.340: the regulation setting the CMIR filing requirement and defining monetary instruments.
• FinCEN: the issuing agency for FinCEN Form 105 and the online filing option.
• U.S. Customs and Border Protection: port guidance, officer presentation of the paper form, and current CBP forms pages.