OMB Control Number 1506-0014
Report of International Transportation of Currency or Monetary Instruments (CMIR) – FinCEN Form 105
1. Circumstances necessitating collection of information.
The legislative framework generally referred to as the Bank Secrecy Act (BSA) consists of the Currency and Foreign Transactions Reporting Act of 1970,1 as amended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act),2 and other legislation, including the Anti-Money Laundering Act of 2020 (AML Act).3 The BSA is codified at 12 U.S.C. 1829b and 1951–1960, 31 U.S.C. 5311–5314 and 5316–5336, including notes thereto, with implementing regulations at 31 CFR chapter X.
The BSA authorizes the Secretary of the Treasury (Secretary) to, inter alia, require financial institutions to keep records and file reports that are determined to have a high degree of usefulness in criminal, tax, or regulatory matters, risk assessments or proceedings, or in intelligence or counter-intelligence activities, including analysis, to protect against terrorism, and to implement anti-money laundering/countering the financing of terrorism (AML/CFT) programs and compliance procedures.4 The Secretary has delegated to the Director of FinCEN (Director) the authority to administer the BSA.5
31 U.S.C. 5316 requires, with limited exceptions, that a person, or an agent or bailee of the person, file a report when the person, agent, or bailee knowingly: (i) transports, is about to transport, or has transported monetary instruments6 of more than $10,000 at one time from a place in the United States to or through a place outside the United States, or to a place in the United States from or through a place outside the United States; or (ii) receives monetary instruments of more than $10,000 at one time transported into the United States from or through a place outside the United States. The regulations implementing this statutory requirement are found at 31 CFR 1010.340 and 31 CFR 1010.306.7
31 CFR 1010.306(d) states that CMIRs required to be filed pursuant to 31 CFR 1010.340 must be filed on forms prescribed by the Secretary and all information called for in such form must be furnished. CMIRs may be obtained from Customs and Border Protection (CBP) or FinCEN,8 and may be completed in paper or online via computer or handheld digital device with internet capability, such as a smartphone.9
31 CFR 1010.340(a) requires each person10 who physically transports, mails, or ships; or causes to be physically transported, mailed, or shipped; or attempts to physically transport, mail, or ship; or attempts to cause to be physically transported, mailed, or shipped, currency11 or other monetary instruments12 in an aggregate amount exceeding $10,000 at one time from the United States to any place outside the United States, or into the United States from any place outside the United States, to file a CMIR.13 CMIRs required to be filed pursuant to 31 CFR 1010.340(a) must be filed at the time of entry into the United States or at the time of departure, mailing, or shipping from the United States, unless otherwise specified by the Commissioner of CBP.14 CMIRs required to be filed pursuant to 31 CFR 1010.340(a) for currency or other monetary instruments not physically accompanying a person entering or departing from the United States may be filed by mail on or before the date of entry, departure, mailing, or shipping.15
31 CFR 1010.340(b) requires each person who receives in the United States, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time which have been transported, mailed, or shipped to such person from any place outside the United States, to file a CMIR if the CMIR has not already been filed pursuant to 31 CFR 1010.340(a), whether or not required to be filed thereunder. The CMIR must include the amount, the date of receipt, the form of monetary instruments, and the person from whom the funds were received. CMIRs required to be filed pursuant to 31 CFR 1010.340(b) must be filed within 15 days after receipt of the currency or other monetary instruments.16 All CMIRs required to be filed pursuant to 31 CFR 1010.340 must be filed with the customs officer in charge at any port of entry or departure, or as otherwise specified by CBP, such as by mail.17
31 CFR 1010.340(c) includes a list of persons that are not required to file a CMIR. These include banks, foreign banks, and broker or dealers in securities, with respect to currency or other monetary instruments mailed or shipped through the postal service or by common carrier, and persons engaged as a business in the transportation of currency, monetary instruments and other commercial papers, with respect to the transportation of currency or other monetary instruments overland between established offices of banks or brokers or dealers in securities and foreign persons.18
31 CFR 1010.340(d) clarifies that a transfer of funds through normal banking procedures, which does not involve the physical transportation of currency or other monetary instruments, is not required to be reported on the CMIR. 31 CFR 1010.340(d) also states that no more than one CMIR needs to be filed covering a particular transportation, mailing, or shipping of currency or other monetary instruments with respect to which a complete and truthful CMIR has been filed by a person. However, no person required to file a CMIR under 31 CFR 1010.340(a) or (b) is excused from liability for failure to do so, if in fact, a complete and truthful report has not been filed.
A person transporting, mailing, or shipping the person’s own currency or other monetary instruments in an aggregate amount in excess of $10,000 at one time from the United States to any place outside the United States, or into the United States from any place outside the United States, or receiving such value on their own behalf from a place outside the United States, must provide their own information when completing the CMIR. An individual acting for anyone else when transporting, shipping, mailing, or receiving currency or other monetary instruments in excess of $10,000 must provide (a) the individual’s own information, and (b) information about (i) the person (individual or entity) on whose behalf the transaction was conducted, and, if currency is mailed, (ii) the person from whom the currency or monetary instruments were received, and/or (iii) the person to whom the currency or other monetary instruments were shipped.19
As applicable, records that are required to be retained by 31 CFR chapter X shall be retained for a period of five years.20
2. Method of collection and use of data.
As noted in Section 1, CMIRs may be obtained from CBP or FinCEN, and may be completed in paper or online via computer or handheld digital device with internet capability, such as a smartphone. Pursuant to 31 CFR 1010.340(a), CMIRs must be filed at the time of entry into the United States or at the time of departure, mailing, or shipping from the United States. Pursuant to 31 CFR 1010.340(a), CMIRs for currency or other monetary instruments not physically accompanying a person entering or departing from the United States may be filed by mail on or before the date of entry, departure, mailing, or shipping. Pursuant to 31 CFR 1010.340(b), each person who receives in the United States currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time that has been transported, mailed, or shipped to such person from any place outside the United States, must file a CMIR if a CMIR has not already been filed. Pursuant to 31 CFR 1010.340(b), the CMIR must include the amount, the date of receipt, the form of monetary instruments, and the person from whom the funds were received, and must be filed within 15 days after receipt of the currency or other monetary instruments.
The information collected may be used for purposes consistent with the BSA21 including assisting law enforcement in anti-money laundering, tax, and other financial investigations; advancing counterterrorism, counter-proliferation, and broader national security and intelligence interests; improving financial institutions’ ability to assess and mitigate risk; helping prevent evasion of financial sanctions; facilitating tax compliance; enhancing financial transparency; and advancing U.S. compliance with international standards and information sharing commitments.
3. Use of improved information technology to reduce burden.
In early 2020, CBP implemented a web-based platform for the electronic completion of CMIRs by travelers transporting their own currency or other monetary instruments. Travelers using this platform must still present evidence of the electronic completion of the report to the CBP officer in charge at any port of entry or departure.22
4. Efforts to identify duplication.
FinCEN has reviewed government and commercial databases to identify duplication. FinCEN has determined there are no government or commercially available sources of information that could be used or modified by FinCEN in duplicating the information provided in CMIR filings. There are also no Federal rules that directly or fully duplicate or overlap with the information that may be collected and provided in CMIR filings. Therefore, there is no information already available to the Federal government that could be used or modified by FinCEN to fully satisfy the statutory and regulatory requirements identified in Section 1 above or that fully serve the uses identified in Section 2 above.
5. Methods to minimize burden on small businesses or other small entities.
The reporting requirements of these regulations and form are not expected to impose adverse impacts unique to small businesses or other small entities. The information required to be reported on the CMIR is basic identifying and transaction information which would be readily accessible to an individual transporting, or receiving, currency or other monetary instruments either on the individual’s own behalf or on behalf of any other individual or entity.
Moreover, the reporting requirements apply only when certain conditions are met, thus minimizing burden on small businesses or other small entities. Specifically, pursuant to 31 CFR 1010.340(a), a person, or an agent or bailee of a person, is required to file a CMIR when a person physically transports, mails, or ships; or causes to be physically transported, mailed, or shipped; or attempts to physically transport, mail, or ship; or attempts to cause to be physically transported, mailed, or shipped, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time from the United States to any place outside the United States, or into the United States from any place outside the United States. Similarly, pursuant to 31 CFR 1010.340(b), a person, or an agent or bailee of a person, is required to file a CMIR when a person receives in the United States, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time which have been transported, mailed, or shipped to such person from any place outside the United States.
6. Consequences of less frequent collection on Federal programs or policy activities.
The reporting requirements of the CMIR are generally intended to help law enforcement and regulatory authorities detect, investigate, and prosecute money laundering and other financial crimes by preserving an information trail about reportable transactions involving certain transportation of currency or monetary instruments. Since the CMIR may be filed at the time, or as applicable, within 15 days, when currency or other monetary instruments of more than $10,000 are transported into or out of the United States, a failure to collect this information could hamper law enforcement efforts to detect illegal activity while it is still ongoing and discernible. The timely reporting of this information may provide law enforcement with important investigative leads to take appropriate action, including tracing criminal proceeds, gathering additional evidence, seizing funds, and stopping the movement of funds before criminal elements can change their schemes for disposing of the profits of illegal activity.
7. Special circumstances requiring data collection to be inconsistent with guidelines.
Pursuant to 31 CFR 1010.430(d), all records that are required to be retained by 31 CFR Chapter X must be retained for a period of five years. Records must be kept for five years because such records may relate to substantive violations of law that are subject to statutes of limitation longer than three years.
8. Consultation with individuals outside of the agency on availability of data, frequency of collection, clarity of instructions and forms, and data elements.
On June 18, 2025, FinCEN published in the Federal Register a 60-day notice and request for comments of its intention to renew, without change, information collection requirements relating to reports of international transportation of currency or monetary instruments.23 The 60-day comment period closed on August 18, 2025. In response to the notice, FinCEN received two comments. The first comment noted that the $10,000 threshold for filing CMIRs has been in place for a very long time, and recommended the threshold be increased to $15,000. The second comment, as FinCEN understood it, recommended the use of CMIRs in the context of suspicious activity reports.
Overall, FinCEN determined there were no recommendations or objections with respect to the information collection being renewed or comments associated with the estimated burden or cost of the information collection being renewed that require revision to the analysis presented in the Federal Register 60-day notice and request for comments.
9. Explanation of decision to provide any payment or gift to respondents.
No payments or gifts were made to respondents.
10. Assurance of confidentiality of responses.
The information collected will be made available to the Department of the Treasury, its designee, and other authorized agencies. Such information will be used for purposes consistent with the purposes set forth in 31 U.S.C. 5311, including but not limited to furthering a criminal, tax, or regulatory investigation, risk assessment, or proceeding, or use in intelligence or counterintelligence activities, including analysis, to protect against terrorism.
11. Justification of sensitive questions.
There are no questions of a sensitive nature in the collection of information, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. Any personal identifiers, or identifiable information, collected under the BSA, including the provision that requires CMIRs, is strictly controlled as outlined in the relevant FinCEN Privacy Act Systems of Records Notice for BSA reports.24
12. Estimated annual hourly burden
Frequency: As required.
Estimated Number of Annual Respondents (also referred to as CMIR filers): 108,40025
Estimated Number of Responses: 140,687 reports.26
Estimated Burden per Response: 17.95 minutes, on average.27
Estimated Total Annual Burden Hours: 42,089 hours.28
13. Estimated annual cost burden.
Estimated Cost per Response: $15.99 on average.29
Estimated Total Annual Cost to the Public: $2,250,491.30
FinCEN has not separately estimated, or assigned a dollar value to, the non-labor costs to the public associated with the covered reporting requirements.
14. Estimated Annual Cost to the Federal Government:
FinCEN estimates that the total cost to the federal government, per year, will be approximately $1,613,522.26. This estimate includes the expected costs to both CBP and FinCEN. The annualized expected processing costs expected to be incurred by CBP annually are $1,599,192.36. Estimated costs to CBP include the burden of processing paper filings ($1,299,192.3631) and electronic filings ($300,000.0032). Additionally, FinCEN estimates that it will incur annual data upload and storage costs of approximately $14,329.90 based on an assigned annual cost of $0.10 per CMIR, times the number of reports it expects to process annually (143,299 reports).33
15. Reasons for change in burden.
The estimated total annual burden hours decreased by 7,662 hours, from 49,751 hours in 2022 to 42,089 hours in 2025. This difference in expected aggregate burden reflects two primary revisions. First, the expected time burden per response was revised, resulting in an increase in the weighted average time per report from 16.16 minutes in 2022 to 17.95 minutes in 2025.34 Second, the estimated number of responses per year was revised to reflect data from the most recent historical three-year period, resulting in a reduction in the estimated number of responses expected annually from 184,709 in 2022, to 140,687 in 2025. Because the decrease in the expected number of responses per year outweighs the minor increase in the weighted average of expected time burden per response, the overall effect of the revisions was a decrease in expected aggregate burden.
The increase in the associated estimate of total cost to the public, from $1,859,471 in 2022 to $2,250,491 in 2025, is attributable to both general increases in wage rates from 2022 to 2025 and FinCEN’s revisions to the attribution of varying wage rates to responses dependent on filing and filer types.35
Expected annual costs to the federal government also increased from $1,434,835 in 2022 to $1,613,522 in 2025. This increase is primarily due to an increase in the estimated costs to CBP of processing paper CMIR forms.
16. Plans for tabulation, statistical analysis, and publication.
This collection of information will not be tabulated or compiled for publication.
17. Request not to display the expiration date of the OMB control number.
FinCEN requests that it not be required to display the expiration date of the control number so that the regulations and the CMIR will not have to be amended for new expiration date every three years, or earlier, as applicable. This request will not affect the normal three-year PRA renewal process.
18. Exceptions to the certification statement.
There are no exceptions to the certification statement.
1 Title II of Pub. L. 91–508, 84 Stat. 1118 (Oct. 26, 1970).
2 USA PATRIOT Act, Pub. L. 107–56, 115 Stat. 272 (Oct. 26, 2001).
3 The AML Act was enacted as Division F, sections 6001-6511, of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, Pub. L. 116-283, 134 Stat. 3388 (Jan. 1, 2021).
4 See 31 U.S.C. 5311(1)-(2). Reporting requirements are authorized under other provisions in the BSA. See 31 U.S.C. 5313 (Currency Transaction Reports, or CTRs); 31 U.S.C. 5314 (Report of Foreign Bank and Financial Accounts, or FBARs); 31 U.S.C. 5318(a)(2) (authorizing the Secretary to impose reporting requirements for the purpose of ensuring compliance with the BSA or guarding against money laundering, the financing of terrorism, or other forms of illicit finance); 31 U.S.C. 5318(g) (Suspicious Activity Reports, or SARs); 31 U.S.C. 5330 (Registration of Money Services Businesses, or RMSBs); 31 U.S.C. 5331 (Report of Cash Payments Over $10,000 Received in a Trade or Business, or Form 8300s).
5 See Treasury Order 180-01 (reaffirmed Jan. 14, 2020); see also 31 U.S.C. 310(b)(2)(I) (providing that the Director of FinCEN shall “[a]dminister the requirements of subchapter II of chapter 53 of this title, chapter 2 of title I of Public Law 91–508, and section 21 of the Federal Deposit Insurance Act, to the extent delegated such authority by the Secretary.”).
6 For purposes of 31 U.S.C. 5316, monetary instruments are defined at 31 U.S.C. 5312(a)(3).
7 See specifically 31 CFR 1010.306 (b), (d), and (e).
8 31 CFR 1010.306(e).
10 FinCEN regulations define a “person” as an individual, a corporation, partnership, a trust or estate, a joint stock company, an association, a syndicate, joint venture or other unincorporated organization or group, an Indian Tribe (as that term is defined in the Indian Gaming Regulatory Act), and all entities cognizable as legal personalities. 31 CFR 1010.100(mm). In this supporting statement, persons who are associated with the transportation, mailing, or shipment of currency or other monetary instruments completed in their capacity as individuals (on their own behalf or for another individual) are referred to as “individuals.” All types of persons that are not individuals, but for whom a transportation, mailing, or shipment of currency or other monetary instruments that requires the submission of a CMIR is completed are referred to as “entities.” While FinCEN believes this use of terminology is generally consistent with classification and discussion elsewhere, such as in previous OMB control renewals (see, e.g., FinCEN, Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of the Report of International Transportation of Currency or Monetary Instruments; FinCEN Report 105, 90 FR 26090 (June 18, 2025), (the 2025 CMIR PRA Renewal); see also FinCEN, Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of the Report of International Transportation of Currency or Monetary Instruments, 87 FR 16548 (Mar. 23, 2022)), and the electronic format and filing instructions of the CMIR (CMIR general instructions, available at https://www.fincen.gov/sites/default/files/shared/fin105_cmir.pdf.), this classification may, in some cases differ from the terminology employed in other public documents discussing CMIR obligations.
11 FinCEN regulations define currency at 31 CFR 1010.100(m).
12 FinCEN regulations define monetary instruments at 31 CFR 1010.100(dd).
13 A person is deemed to have caused such transportation, mailing or shipping when he or she aids, abets, counsels, commands, procures, or requests it to be done by a financial institution or any other person. See 31 CFR 1010.340(a).
14 31 CFR 1010.306(b)(1) and (b)(3).
15 31 CFR 1010.306(b)(3).
16 31 CFR 1010.306(b)(2).
17 31 CFR 1010.306(b)(3).
18 31 CFR 1010.340(c)(2), (9).
19 See 31 CFR 1010.340(a), (b). See also FIN-2014-G002 (Aug.1, 2014) (CMIR guidance for common carriers of currency, including armored car services), available at https://www.fincen.gov/resources/statutes-regulations/guidance/cmir-guidance-common-carriers-currency-including-armored. CMIR general instructions, available at https://www.fincen.gov/sites/default/files/shared/fin105_cmir.pdf.).
20 31 CFR 1010.430(d).
21 See, e.g., 31 U.S.C. 5311.
22 See supra note 9.
23 See supra note 10, the 2025 CMIR PRA Renewal.
24 FinCEN, Privacy Act of 1974, as Amended; System of Records Notice (FinCEN .003 - Bank Secrecy Act Reports System), 79 FR 20969 (Apr. 14, 2014).
25 This estimate is based on the number of identifiably unique filers associated with CMIRs filed in calendar year 2024, which included approximately 100,000 individuals and 8,400 entities. See the 2025 CMIR PRA Renewal.
26 This estimate is based on the average number of identifiably required CMIRs filed (i.e., filings for reported amounts over $10,000) in the calendar years 2022-2024. See supra note 10, the 2025 CMIR PRA Renewal.
27 See supra note 10, the 2025 CMIR PRA Renewal.
28 Id.
29 Id.
30 Id.
31 Based on data provided by the CBP, processing paper CMIRs cost $974,394.27 during the nine months between June 30, 2023 and March 31, 2024, which is equivalent to an annualized cost of $1,299,192.36.
32 Based on data provided by CBP, processing electronic CMIRs costs approximately $300,000 per year.
33 Although FinCEN estimates only 140,687 required reports, annually, on average, FinCEN anticipates processing a higher volume of 143,299 total reports over the same period due to the additional inflow of CMIRs that appear to be filed voluntarily (approximately 2,612 per year, on average).
34 In 2022, FinCEN’s per response assigned time burdens were: (i) 15 minutes per report filed by travelers reporting transactions involving their own currency or monetary instruments, and (ii) 30 minutes per report filed by currency transporters reporting transactions on behalf of others. In 2025, FinCEN revised its estimated time burdens to: (i) 15 minutes per report filed by individuals reporting transactions involving their own currency or monetary instruments, (ii) 25 minutes per report filed by individuals reporting transactions on behalf of other individuals, and (iii) 20 minutes per report filed by entities reporting transactions on behalf of their business.
35 See FinCEN, Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of the Report of International Transportation of Currency or Monetary Instruments; FinCEN Report 105, 87 FR 16548 (Mar. 23, 2022).
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement |
| Author | StephR |
| File Modified | 0000-00-00 |
| File Created | 2025-09-25 |