Over three days in June 2014, CBP officers at Philadelphia International Airport seized a combined $188,830 from three unrelated sets of arriving travellers. A man from Ghana lost $39,500. A couple arriving from Iraq via Qatar lost $111,000. A U.S. citizen and his wife, a lawful permanent resident, lost $38,330.
None of the five were criminally charged. All were released the same day.
The timing of the second case is worth noticing. That week, Mosul had just fallen and the security situation across northern Iraq was collapsing. A couple arriving from Iraq via Qatar, carrying dollars, dinars and riyals in six bundles and loose notes, is a recognisable pattern to anyone who does this work: a family leaving somewhere dangerous with as much of what they own as they could physically carry.
Why People Leaving a Crisis Carry Cash
The question people ask about these cases is why anyone would move six figures physically rather than wiring it. For travellers coming out of a country in crisis, the answer is usually that wiring was not available.
- Banks close, impose withdrawal limits, or stop honouring transfers when a security situation deteriorates.
- Correspondent banking relationships are withdrawn from markets under stress, so even functioning local banks cannot move money abroad.
- Sanctions regimes can block ordinary transfers entirely, including for people with no connection to the conduct being sanctioned.
- Departures are often decided in days. There is no time to arrange a transfer even where one is theoretically possible.
- Where the currency is depreciating rapidly, people convert to dollars and hold physical notes because the alternative is watching savings evaporate.
None of that changes the obligation. The requirement to report more than $10,000 on FinCEN Form 105 applies to every traveller identically, with no exception for hardship, urgency, or the circumstances that produced the cash. It is worth saying plainly, because the reverse assumption is common and costly.
Why This Group Under-Reports
The Iraqi couple declared $10,000 and some Iraqi currency. They were carrying $111,000 more than that. The Ghanaian traveller declared $9,400 and 80 Euros against roughly $39,500. Both figures look, on paper, like deliberate understatement.
Sometimes they are. Frequently the explanation is more ordinary, and it repeats across cases:
- Nobody knew the rule existed. The reporting requirement is not intuitive and is not announced anywhere most travellers would encounter it before arriving.
- They knew a number but not the rule. “Ten thousand” circulates as a limit on how much you may bring rather than a reporting threshold, so people declare a figure at or just under it believing that is what compliance looks like.
- Declaring money to a uniformed official is dangerous where they come from. In a great many countries, telling an official at a border that you are carrying substantial cash is how you stop having it. That instinct does not switch off on arrival in Philadelphia.
- Language. Questions asked quickly, in English, at the end of a multi-leg journey out of a war zone, are not reliably understood.
- Exhaustion. Iraq to Qatar to Philadelphia is a long way, and precision about the contents of six bundles is not what people are best at on arrival.
The Mitigating Factors Were Written for These Cases
This is the part that matters practically, and it is why a case like this is worth fighting rather than abandoning.
CBP’s mitigation guidelines for currency reporting violations allow officers to reduce the standard amount by up to ten percent for each recognised mitigating factor, capped at thirty percent. The recognised factors are a language barrier or a physical or mental condition that impaired understanding of the requirement, inexperience in international travel, and cooperation beyond what would normally be expected.
And there is a humanitarian provision
Separately from the ten percent factors, the guidelines recognise a category of extraordinary mitigating factors that can justify remitting all or a significant portion of the standard amount. Among them is special humanitarian justification. A family that left a collapsing security situation with its savings is the circumstance that language exists to address, and it has to be raised and evidenced rather than assumed.
A petition built on these facts is not a plea for sympathy. It is an argument that the specific factors CBP has committed to weighing are present, supported by evidence: documentation of the circumstances of departure, of where the money came from, of what it is for, and of the traveller’s history and language capability. That is what a petition for remission or mitigation is built to do.
Consecutively Numbered Bills Cut Both Ways
One detail in the third seizure deserves a second look. CBP noted that officers found “three bundles of consecutively numbered $100 bills,” reported in a tone suggesting the fact was incriminating.
Consider what produces consecutively numbered notes. They come out of a bank in sequence, in a strap, from a single withdrawal. Money that has moved through informal hands, changed owners repeatedly, or been assembled from many small transactions is not consecutively numbered. A sequential run is the signature of a documented institutional withdrawal.
Turn it into evidence rather than leaving it as an allegation
If your money was withdrawn from a bank, the serial numbers are a thread back to the withdrawal slip, the account statement and the branch. That is precisely the documented legitimate source a petition needs. A claimant who says nothing leaves the observation sitting in the file as an unexplained oddity; a claimant who produces the withdrawal record converts it into corroboration.
Released Without Charges Is Not the End
None of the five travellers was charged. That is meaningful: it suggests CBP did not consider the money connected to criminal activity, which is the single most important fact in any petition that follows.
It is also the moment where money is most often lost by default. People who walk out of an airport without handcuffs conclude the matter is closed. It is not. A Notice of Seizure follows by mail with an election of proceedings form and a response deadline that is ordinarily 30 days, and the currency is forfeited administratively if nobody answers it.
For travellers who have just arrived in an unfamiliar country, possibly at a temporary address, possibly without reliable mail, that risk is considerably higher than for a resident. Confirm what address CBP has. Keep the custody receipt. Our page on why claimants should not call CBP after a currency seizure covers what not to do next, our page on how to get seized cash back from CBP covers the options and deadlines, and our page on cash seized at Philadelphia International Airport covers the local process. Outcomes depend heavily on the specific facts and the documentation available.
Cash Seized on Arrival?
Great Lakes Customs Law handles currency seizures at airports nationwide, including cases involving language barriers and travellers new to the United States. Contact us for a confidential case evaluation.
Frequently Asked Questions
I was bringing my savings to the U.S. because my country is unsafe. Does that matter?
It does not change the reporting obligation, which applies to everyone. It matters a great deal to a petition afterwards. CBP’s guidelines recognise special humanitarian justification as an extraordinary mitigating factor, alongside language barriers and inexperience in international travel.
I did not understand the question I was asked. Is that a defence?
Not a defence to the violation, but a language barrier that impaired understanding of the requirement is a named mitigating factor worth up to a ten percent reduction, with a thirty percent cap across all factors. It has to be raised and supported.
CBP noted my bills were consecutively numbered. Is that bad?
Not necessarily. Sequential notes come from a single bank withdrawal, which is exactly the documented legitimate source a petition needs. Produce the withdrawal record and account statement and the observation becomes corroboration rather than suspicion.
We were released without charges. Do we still need to do anything?
Yes. Civil forfeiture proceeds independently of any criminal referral. A Notice of Seizure follows by mail with a short deadline, and the money is forfeited by default if nobody responds. Make sure CBP has an address where you will actually receive mail.
Legal Disclaimer: This article is provided for general informational purposes only and does not constitute legal advice. Reading it, or contacting Great Lakes Customs Law through this website, does not create an attorney-client relationship. The circumstances of the travellers described here are drawn from a public CBP news release; observations about why people in similar situations carry cash are general and are not statements about these individuals. Great Lakes Customs Law does not practise immigration law, and any immigration questions should be evaluated by qualified immigration counsel. CBP’s mitigation guidelines govern that agency’s internal operations and create no right, privilege or benefit for any person. Laws, regulations and CBP procedures change, and the outcome of any customs seizure or forfeiture matter depends heavily on its specific facts and circumstances. No result is guaranteed or implied. You should consult a licensed attorney about your particular situation before taking or refraining from any action.