CBP officers and HSI agents at Washington Dulles International Airport seized more than $60,000 from a Gambian national after a series of escalating misreports — each one making his situation significantly worse than the last. The full CBP account of what happened:
On Saturday, CBP officers and Homeland Security Investigations agents discovered $64,770 in U.S. dollars that the Gambian man had concealed throughout his possessions. The man initially reported to two CBP officers separately that he did not possess more than $10,000. After CBP explained the currency reporting requirements, the man then reported that he possessed no more than $14,000. After an initial baggage examination revealed $44,750, the man completed a U.S. Treasury currency reporting form reporting $44,750. A subsequent examination of a carry case revealed an additional $20,000. CBP seized $61,770, released $3,000 to the man for humanitarian purposes, and then released him.
Four Separate Mistakes — Each One Compounding the Last
This case is worth walking through step by step because it illustrates exactly how a currency seizure goes from bad to catastrophic through a series of individually avoidable decisions.
Mistake one: He almost certainly indicated on his traveler’s declaration form that he was not carrying more than $10,000. That written declaration is the first documented false statement on his record — made before he ever spoke to an officer. This is a failure to report under 31 U.S.C. § 5316 in its most basic form.
Mistake two: When CBP officers asked him orally — separately, on two occasions — whether he had more than $10,000, he denied it. That denial is a second false statement, and the fact that two different officers asked and received the same false answer suggests he was given multiple opportunities to correct the record and declined each time.
Mistake three: When CBP explained the reporting requirements and gave him another opportunity to declare accurately, he reported $14,000 — still dramatically short of the $64,770 he was actually carrying. He then completed a FinCEN 105 form reporting only $44,750 after officers found that amount in his bags. Filing an inaccurate FinCEN 105 — even after being given the opportunity to report correctly — is a material false statement on a federal form.
Mistake four: The currency was concealed throughout his possessions — not sitting openly in a bag, but distributed and hidden in a way that CBP had to find through successive examinations. That concealment is the factual predicate for a bulk cash smuggling allegation under 31 U.S.C. § 5332, which carries substantially higher civil penalty exposure than a straightforward failure to report.
The Critical Misconception: Only the Unreported Amount Gets Seized
One of the most persistent misconceptions about currency seizures is the belief that CBP can only seize the amount above the reported figure — that if you declare $14,000 and are found to have $44,750, CBP can only take the $30,750 difference. That is wrong.
Under 31 U.S.C. § 5317, the entirety of the currency is subject to seizure when a reporting violation occurs — not just the unreported portion. In this case, even though $14,000 was eventually reported on a FinCEN 105, CBP seized $61,770 — essentially everything except the $3,000 released for humanitarian purposes. The reported amount provided no protection for the money above it, and it provided no protection for itself either, because the report was filed after CBP had already discovered currency and after multiple false statements had been made.
This misconception sometimes leads people to believe that filing a partial declaration gives them partial protection. It does not. An inaccurate declaration is a violation in its own right, and the government’s forfeiture authority covers the full amount of currency involved in the violation. If you are in this situation, read our guide on how the petition for remission or mitigation works before taking any other steps.
CBP’s Practice of Giving Opportunities to Amend
Despite what happened here, CBP does routinely give travelers the opportunity to amend their declarations before a seizure occurs. In many cases — particularly at airports where the enforcement culture tends toward education as much as enforcement — a traveler who initially misreports but corrects their declaration when given the chance ends up in a meaningfully better position than one who maintains a false report through multiple opportunities to correct it.
The Gambian traveler in this case was given that opportunity multiple times. He was asked by two officers. CBP explained the reporting requirements to him. He was given a form to complete. At each step, he provided an amount significantly lower than what officers subsequently found. By the time the full $64,770 was discovered, the record showed a pattern of escalating misrepresentation rather than a single innocent mistake. That pattern will be the central challenge in any petition for return of the funds. See our currency seizure case outcomes for examples of how these cases resolve in practice.
HSI’s Involvement
HSI agents were present and involved in the examination — which means this case was treated from the outset as a potential criminal matter, not just a civil forfeiture. The man was released without criminal charges, but HSI’s involvement signals that the government was evaluating whether the currency was connected to something beyond a reporting violation. At Dulles, which handles significant direct traffic to West Africa, outbound cash enforcement is treated seriously and HSI presence at examinations is not unusual in cases involving large amounts and concealment.
Being released without criminal charges is not the same as the matter being closed. The civil forfeiture proceeds on its own track regardless of whether criminal charges are filed. Read our guide on why you must not contact CBP without an attorney after a seizure of this kind — anything said to HSI or FP&F without counsel can affect both the civil and any potential criminal proceedings.
Has Dulles CBP Seized Your Cash?
If CBP at Dulles seized your currency, contact us before doing anything else. Dulles FP&F is among the most aggressive offices in the country, and a record showing multiple misrepresentations — as in this case — requires particularly careful handling in the petition process. Read our dedicated page on cash seizures at Dulles Airport and our full customs money seizure legal guide, or watch the video series. Call us at (734) 855-4999, send a text message, or reach us on WhatsApp. You can also contact us online.