Here’s What to Do.
Philadelphia International Airport handles international flights across the Atlantic to Europe, the Caribbean, the Middle East, and West Africa — routes that bring consistent CBP currency enforcement activity at PHL. While Philadelphia is not among the highest-volume seizure airports in the country, CBP conducts both inbound and outbound enforcement operations here, and the consequences of an unreported currency violation are the same regardless of the port. If your cash has been seized at PHL, you need to act quickly and you need experienced legal counsel before you respond to CBP in any way.
Do not call CBP’s Fines, Penalties and Forfeitures office to explain yourself. Do not submit any written statement or documentation without an attorney reviewing your case first. The administrative forfeiture process is adversarial, deadlines are strict, and every statement you make after a seizure is part of the record.
Great Lakes Customs Law has handled currency seizure cases at Philadelphia International Airport and at ports of entry nationwide. Read on to understand what happened, what you are facing, and how we can help.
Currency Enforcement at PHL: What You Need to Know
Philadelphia’s international routes connect the mid-Atlantic region to the United Kingdom, continental Europe, the Caribbean, Qatar, and West Africa. These corridors — particularly flights to Nigeria, Jamaica, Qatar, and the Palestinian territories — have been the subject of documented CBP enforcement actions at PHL in recent years.
CBP’s press releases document several significant outbound seizures at Philadelphia. In one case, a New Jersey man departing for Nigeria was found to be carrying more than $200,000 in unreported currency — CBP’s third-largest unreported currency seizure at the Area Port of Philadelphia since the agency’s founding in 2003. In another case, a family departing for Qatar verbally declared $65,000, wrote $65,000 on their FinCEN form, and were found to be carrying nearly $100,000. CBP seized $93,000 and returned $3,393. In a separate case, a couple departing for Jamaica declared $6,050 but were found to be carrying nearly $45,000 in cash packed in envelopes inside clothing in their luggage.
These cases share a common thread: the travelers were not carrying funds from criminal activity, but their failure to accurately report — or in some cases, their decision to deliberately underreport — gave CBP full legal authority to seize the money. The reporting requirement does not distinguish between legal and illegal funds.
Common Reasons CBP Seizes Cash at PHL
Under 31 U.S.C. § 5316, any person traveling internationally with more than $10,000 in currency or monetary instruments must file a FinCEN 105 form with CBP at the time of arrival or departure. The requirement applies equally to U.S. citizens and foreign nationals, and to both inbound and outbound travel. The most common violations at PHL include:
- Failure to report on departure — Cash being carried out of the United States on an international flight without a FinCEN 105 filing, or with an inaccurate declaration. Outbound enforcement is a consistent enforcement priority at PHL, particularly on flights to Africa and the Caribbean.
- Inaccurate reporting — Declaring an amount less than what is actually being carried. CBP does not treat a partial declaration as compliance — any material discrepancy between what is declared and what is found gives CBP grounds to seize the full amount.
- Failure to report on arrival — Travelers arriving on international flights who do not declare currency over $10,000 at the time of entry.
- Bulk cash smuggling — Currency concealed in clothing, luggage, or personal effects with intent to evade the reporting requirement, charged under 31 U.S.C. § 5332. This is the most serious violation and carries the highest forfeiture exposure.
- Structuring — Dividing funds among travel companions to keep individual amounts below $10,000, charged under 31 U.S.C. § 5324.
Inaccurate Declarations: A Common Trap at PHL
Several documented PHL cases involve travelers who did attempt to declare their currency — but declared an amount significantly less than what they were actually carrying. This matters because a partial declaration does not protect you. Under federal law, the reporting requirement is to accurately report the full amount. If CBP finds a material discrepancy, the entire amount is subject to seizure, not just the undeclared portion.
This is a critical distinction. Travelers who believe they have partially complied with the law by declaring something are often surprised to learn that underreporting has the same legal consequence as not reporting at all. If you are in this situation, an experienced customs attorney can help you build a case that addresses the facts of your declaration in the context of the petition process.
What Happens After a Cash Seizure at PHL
At the time of seizure, CBP will issue a Custody Receipt for Seized Property. Within 60 days, the Fines, Penalties and Forfeitures office will send a Notice of Seizure and Information to Claimants by certified mail, along with the Election of Proceedings form. You must choose how to respond. Your three options are:
- Administrative Petition for Remission or Mitigation — You ask CBP to return all or part of the money through an internal review, keeping the matter out of federal court. A well-constructed petition demonstrating the legitimacy of the funds is the most common path to recovery.
- CAFRA Seized Asset Claim — You formally contest the seizure and demand federal court proceedings, placing the burden of proof on the government.
- Offer in Compromise — You propose a settlement, paying a portion of the seized amount in exchange for return of the remainder.
Read our detailed guide to the Election of Proceedings form and our analysis of which option is best for your situation.
Act Before the Deadline
Once the Notice of Seizure is issued, you generally have 30 days to file an Election of Proceedings. Miss that deadline and CBP may proceed with administrative forfeiture — the money is gone without any court review. There is no grace period.
Do not contact the FP&F office on your own in the meantime. Do not make any statements about the money or its source without counsel. Read our guide on why you must remain silent after a currency seizure.
What Evidence Will You Need
Regardless of which proceeding you elect, you will need to affirmatively demonstrate that the seized funds came from a legitimate source and were intended for a lawful purpose. The burden falls entirely on you — CBP does not presume legitimacy. Supporting documentation typically includes bank records and withdrawal history, tax returns and income documentation, business records and contracts, statements from family members or business partners, currency exchange records, and any documentation specific to the circumstances of your travel or the intended use of the funds.
Read our full guide to evidence and documentation for currency seizure cases.
Philadelphia’s CBP Area Port
Currency seizures at Philadelphia International Airport are processed through the CBP Philadelphia Area Port (port code 1101), which falls under the jurisdiction of the CBP Baltimore Field Office. Great Lakes Customs Law works with FP&F offices at ports across the country, including within the Baltimore Field Office jurisdiction, and understands how these offices evaluate and decide seizure cases.
Our Results at PHL and Nationwide
Great Lakes Customs Law has represented clients with currency seizures at Philadelphia International Airport and at ports of entry across the country. Jason Wapiennik has handled more than 700 currency seizure cases and recovered more than $11 million for clients nationwide. Federal currency seizure law is uniform across all U.S. ports — you do not need a Pennsylvania-based attorney to contest a PHL seizure effectively.
See our currency seizure case results.
Get a Free Consultation Today
If CBP has seized your cash at Philadelphia International Airport, contact us now for a free currency seizure consultation. The sooner we review your case, the more options are available to fight for a full recovery.
Read our full CBP Money Seizure Lawyer’s Guide or reach out directly using the contact options on this page.