Criminals physically carry large-value banknotes (for example, €500 or CHF 1000) across borders to reduce the bulk and weight of illicit funds. A cache of smaller-denomination notes that might weigh 15–20 kg and fill a sports bag can be compressed into the equivalent value in €500 bills weighing roughly 0.6 kg and fitting in a single envelope, greatly simplifying concealment. Investigations show that some money service businesses knowingly supply large-denomination notes to criminals, further enabling stealth transport outside formal banking channels. Although certain jurisdictions have restricted or ceased issuing high-denomination notes, demand remains high in areas with weak oversight or through complicit exchange services, allowing offenders to continue discreetly moving large sums undetected.
High-Denomination Currency Transport
High-Denomination Currency Utilization
Tactics
Criminals physically transport high-denomination banknotes (e.g., €500 or CHF 1000) across borders to minimize the physical bulk of illicit funds. This reduces the likelihood of detection during inspections and enables the covert movement of proceeds outside formal banking channels.
Risks
Criminals physically transport high-denomination banknotes across borders, bypassing formal banking channels and reporting mechanisms. By compressing large sums into fewer high-value notes, they reduce detection risk during inspections and effectively move proceeds outside standard oversight.
Offenders exploit cross-border differences in regulations where certain jurisdictions still allow or issue high-value notes. By choosing regions with weaker oversight or restrictions, they can acquire and transport large sums with minimal scrutiny, and this reduces the risk of detection and interception.
Indicators
Customer frequently deposits or withdraws large-denomination notes (e.g., €500 bills) in amounts inconsistent with their stated cash usage history.
Repeated currency exchange from high-value notes into smaller denominations (or vice versa) shortly before or after international travel.
Customer declares minimal currency at border crossings but subsequently deposits significant volumes of high-denomination bills upon return.
Pattern of travel to jurisdictions where high-denomination bills are prevalent, followed by deposits of these note types in local accounts.
Large or repeated requests for high-denomination notes from money service businesses lacking legitimate commercial justification.
Data Sources
Captures declared currency amounts, traveler details, and cross-border entry/exit logs. Cross-referencing these data with subsequent deposits or withdrawals of high-denomination notes can reveal undeclared currency movements tied to illicit transport.
Highlights jurisdictions where high-denomination bills remain in frequent use or are subject to weak oversight. Correlating travel to these regions with unusual note transactions helps uncover potential cross-border cash smuggling activities.
Detailed records of currency conversions, including spot trades, timestamps, exchange rates, and settlement details. Analyzing these data alongside travel records can reveal suspicious exchanges of large notes for smaller denominations (or vice versa), indicating possible physical transport of illicit funds.
Comprehensive records of financial transactions, including note denominations, timestamps, and associated account details. Correlating the repeated use of large-value notes with cross-border activity helps detect the concealed transport of illicit funds.
Lists licensed money service businesses with their licensing status and operational details. Validating whether an MSB is registered or has any red flags helps uncover unlicensed or complicit providers supplying large-denomination notes for illicit cross-border transport.
Contains verified identity details, expected cash usage profiles, and beneficial ownership information. Comparing declared usage against actual requests for or deposits of high-value currency helps identify suspicious inconsistencies tied to cross-border note transport.
Mitigations
Identify jurisdictions that are still issuing or heavily using large-value banknotes and rate them as higher risk. Apply enhanced controls, such as Enhanced Due Diligence (EDD) and stricter service restrictions, to transactions or customers connected with these regions. This approach reduces the likelihood of undetected bulk cash transport across borders.
Apply deeper scrutiny to customers frequently requesting, withdrawing, or depositing high-denomination notes. Verify the source of funds, intended use, and reason for cross-border travel where relevant. This specifically uncovers unsubstantiated cash movements disguised as legitimate, targeting the concealment of illicit funds in large-value currency.
Implement targeted screening rules for requests, deposits, or withdrawals of large-denomination bills. Correlate these events with customer travel patterns, cross-border transactions, or repeated exchange requests to identify potential smuggling of illicit proceeds in physically compact currency.
Enforce systematic reporting of all large cash transactions involving high-denomination notes above defined thresholds. Institutions should capture an auditable record of significant inflows and outflows, increasing the likelihood of detecting and investigating surreptitious cross-border currency movements.
Deny or limit the distribution of high-value banknotes (e.g., €500 or similar) to customers or money service businesses unless they provide legitimate, documented business rationales. By restricting access to large-denomination bills, institutions directly disrupt criminals' ability to acquire compact, high-value currency for stealth cross-border transport.
Instruments
- Criminals purposely seek out large-denomination bills (e.g., €500 or CHF 1000) to significantly reduce the volume and weight of their illicit funds, making concealment and cross-border transport much easier.
- By obtaining these high-value notes—often through complicit or lax money service businesses—they bypass the more rigorous controls commonly imposed by traditional banks.
- This physical form of currency is difficult to trace once it crosses borders, allowing criminals to move proceeds largely undetected and circumvent formal reporting or monitoring requirements.
Service & Products
- Criminals exchange smaller-denomination bills for high-value notes, drastically reducing the bulk and weight of illicit cash.
- Complicit or negligent exchange providers may knowingly facilitate these transactions, bypassing standard banking scrutiny.
- The resulting concentrated cash is easier to conceal and transport across borders undetected.
Actors
Some money services businesses knowingly supply large-denomination notes to criminals by:
- Exchanging smaller bills for high-value denominations (e.g., €500 notes), thereby reducing the physical volume of illicit cash.
- Processing these transactions with minimal scrutiny, enabling criminals to move concentrated currency undetected across borders.
This circumvents typical bank-level monitoring and creates gaps in reporting requirements for financial institutions.
Illicit operators physically transport high-denomination banknotes across borders to reduce the size and weight of criminal proceeds. They often rely on complicit or lax currency exchange services to acquire large-value notes, limiting formal records and hindering financial institutions' ability to detect suspicious movements.
Cash couriers physically transport large-value notes across borders, significantly reducing the bulk and weight of illicit funds. By bypassing formal banking channels, they limit transaction records and oversight, making it more difficult for financial institutions to trace or detect suspicious currency movements.
References
FATF (Financial Action Task Force) and MENAFATF. (2015, October). Money laundering through the physical transportation of cash. FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Ml-through-physical-transportation-of-cash.html
Financial Action Task Force (FATF). (2015, October). Money laundering through the physical transportation of cash. FATF. http://www.fatf-gafi.org/publications/methodsandtrends/documents/ml-through-physical-transportation-of-cash.html
Sands, P., Campbell, H., Keatinge, T., Weisman, B. (2017, September). Limiting the use of cash for big purchases: Assessing the case for uniform cash thresholds. Royal United Services Institute for Defence and Security Studies. https://www.rusi.org/explore-our-research/publications/occasional-papers/limiting-use-cash-big-purchases-assessing-case-uniform-cash-thresholds