International travel surged after the removal of pandemic-era restrictions, and Thanksgiving travel historically produces a spike in CBP enforcement activity at major international airports. Dulles, as usual, provides the story. A married couple departing for Ghana had their money seized after officers found currency concealed inside a carry-on bag’s zippered liner — well beyond what the couple had declared. Here is the full CBP account:
CBP officers seized the unreported currency while conducting enforcement operations on a Ghana-bound flight. A married couple reported to CBP officers that they possessed a combined $10,500. While inspecting the couple’s carry-on bag, officers discovered an envelope concealed behind the carry-on bag’s zippered liner. Officers verified the couple’s combined currency at $23,641. Officers seized the currency for violating U.S. currency reporting laws and then released the couple with $641 as a humanitarian relief. CBP is not releasing the travelers’ names because none were criminally charged.
The Declaration Problem
The couple declared a combined $10,500 — notably just above the $10,000 threshold, which means they were aware of the FinCEN 105 reporting requirement and filed something. But filing a report for $10,500 when you are actually carrying $23,641 is not compliance — it is an inaccurate declaration, which is a violation of 31 U.S.C. § 5316 just as surely as filing nothing at all. The requirement is to report the full amount accurately. A partial declaration does not provide any legal protection for the unreported portion, and CBP treats the discrepancy as deliberate underreporting rather than a rounding error.
The fact that they declared exactly $10,500 — the minimum amount that triggers the reporting requirement — suggests they knew the threshold and chose to report just enough to appear compliant while concealing the rest. That inference, combined with the physical concealment described below, is exactly how Dulles CBP will characterize this case in the forfeiture proceedings.
The Concealment Element — and Why It Changes the Case
The currency was not simply sitting in the couple’s bags undeclared. It was hidden in an envelope concealed behind the zippered liner of a carry-on bag — a deliberate act of concealment designed to prevent officers from finding it during a standard inspection. That detail transforms this from a reporting violation into a potential bulk cash smuggling case under 31 U.S.C. § 5332.
As I noted at the outset: Dulles stories almost always contain enough detail to allege bulk cash smuggling. Officers here are experienced, the releases are detailed, and the FP&F office at Dulles is among the most aggressive in the country about pursuing the smuggling characterization when the facts support it. A smuggling finding under § 5332 increases the civil penalty exposure significantly — up to 50% of the seized amount — compared to a straightforward failure to report. It also affects how receptive FP&F is to petition arguments and how much mitigation is available.
The “Humanitarian Relief” Detail
CBP released the couple with $641 — the amount above $23,000, apparently left over after the round-number seizure. This is described as “humanitarian relief” and is a standard practice when CBP seizes currency from travelers who need some money to get home or continue their trip. It is a small grace note in an otherwise complete seizure, and it does not affect the legal proceedings that follow. The couple will receive a Notice of Seizure and will need to go through the election of proceedings process to pursue return of the seized funds. The $641 they were allowed to keep is irrelevant to that process.
Ghana-Bound Travelers at Dulles — A Recurring Pattern
Dulles handles significant direct traffic to West Africa, and Ghana-bound flights in particular appear repeatedly in Dulles enforcement releases. This is not coincidental. Dulles is one of the primary U.S. departure points for travelers sending money to Ghana, and CBP officers conducting outbound enforcement on those flights are experienced with the profile. Travelers carrying cash to support family members, purchase property, or conduct business in Ghana are doing nothing illegal — but they need to report it accurately and in full. The enforcement focus on these flights means the margin for error is essentially zero.
CBP’s release notes a broader statistic worth absorbing: CBP seized an average of approximately $386,000 every day in unreported or illicit currency along U.S. borders in the prior year. That is roughly $140 million annually, across thousands of cases at airports, land ports, and seaports nationwide. The couple in this story is one data point in a very large enforcement program that runs continuously.
What Happens Next — and Why Dulles Is Different
The couple was not criminally charged, which means their path forward runs through CBP’s civil forfeiture process. They will receive a Notice of Seizure from the Fines, Penalties and Forfeitures office and will have approximately 30 days to file their election of proceedings. The options — administrative petition, CAFRA seized asset claim, or offer in compromise — each have different implications and the right choice depends on the specific facts.
I have said this in other Dulles posts and I will say it again: do not attempt to handle a Dulles FP&F case without a lawyer. Unrepresented petitioners at Dulles consistently get worse outcomes than the facts of their cases warrant. The FP&F office there applies its mitigation guidelines strictly, and a petition that does not address the concealment element directly and persuasively will not get the best result available. Read our guide on what not to do after a seizure and contact us before filing anything.
Has Dulles CBP Seized Your Cash?
If CBP at Dulles seized your cash, contact us before doing anything else. Read our customs money seizure legal guide or watch the video series, and reach out for a free consultation using the contact options on this page.