Cross-Border Currency Declaration

Criminals openly declare large sums of cash at border checkpoints to present a veneer of legitimacy. Once abroad, they perform currency exchanges or transfers under the guise of lawful funds, returning the proceeds in different denominations or forms. In many jurisdictions, these declarations are rarely verified or counted in detail, allowing criminals to over-declare the amount upon entry so as to legitimize additional illicit funds later deposited or circulated. Re-using or falsifying declaration records multiple times also enables them to obscure the cash’s true origin, especially if authorities fail to match these records with other cross-border movement data. In other instances, criminals break down large sums into multiple smaller declarations or distribute amounts across several currencies to stay below threshold checks—a tactic sometimes referred to as “smurfing”. Notably, some cases show perpetrators subdividing the declared value into amounts of around USD 8,500 per currency, cumulatively reaching USD 28,000 or more, while remaining below official reporting limits. This official paper trail makes it difficult for investigators to link the declared amounts to their actual illicit source, helping perpetrators circumvent standard anti-money laundering controls.

[
Code
T0122
]
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Name
Cross-Border Currency Declaration
]
[
Version
1.0
]
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Parent Technique
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Tactics
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[
Risk
Jurisdictional Risk
]
[
Created
2025-03-12
]
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Modified
2025-04-02
]

Declared Importation of Foreign Currency for Exchange Operations

Tactics

ML.TA0007
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By openly declaring cash at borders and then converting or transferring it abroad under different denominations or using falsified declaration records, criminals introduce multiple layers of transactions to obscure the funds' illicit origin and hinder investigations.

Risks

RS0004
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Jurisdictional Risk
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Criminals exploit inconsistencies and gaps in cross-border currency declarations across multiple jurisdictions. By declaring (and sometimes over-declaring) large sums and reusing falsified declaration records, they leverage weak or uncoordinated verification processes. This allows them to sidestep domestic checks, inflate illicit funds abroad under the guise of official documentation, and ultimately obscure the actual origin of their money.

Indicators

IND00504
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Customer cites customs declarations as the main rationale for significant incoming funds but fails to present supporting evidence of lawful business activities.

IND00512
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Declared funds abroad are exchanged and returned in different denominations or financial instruments, with no transparent audit trail connecting the original declared amount to the final form.

IND00518
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Multiple cross-border trips where declared cash is promptly converted into various monetary forms, then deposited into the same domestic account without justification consistent with the customer’s profile.

IND00526
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High-value cash declarations involve or transit jurisdictions known for weak AML controls, diverging from the usual travel or commercial patterns for the account holder.

IND00527
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Reusing or presenting the same border declaration records for multiple separate financial transactions, causing the total introduced sum to exceed the physically verified declared amount.

IND00532
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Consistently splitting declared amounts into multiple smaller declarations or different currencies below reporting thresholds on repeated cross-border trips, culminating in large aggregated sums.

IND00797
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Frequent high-value cash declarations at international border crossings, followed by immediate conversion into multiple foreign currencies without clear documentation of legitimate sources.

Data Sources

  • Provides official documentation of declared cash amounts and cross-border movements at entry/exit points.
  • Enables verification of the stated amounts against the actual physical movement of currency.
  • Helps detect repeated or suspicious declarations inconsistent with legitimate travel or transactional patterns.
  • Provides risk ratings and AML/CFT enforcement levels across different countries or regions.
  • Identifies high-risk or weakly regulated jurisdictions that may be chosen for cross-border cash declarations.
  • Flags unusual or high-risk routes used to move currency under the guise of legitimate declarations.
  • Logs details of currency conversions, including timestamps, exchange rates, volumes, and trading parties.
  • Allows comparison of exchanged amounts abroad with initially declared sums.
  • Facilitates detection of layering or disproportionate exchanges used to disguise the origin of funds.
  • Includes account ownership details, balances, and transaction histories.
  • Supports comparison of deposits with amounts declared at borders or exchanged abroad.
  • Detects mismatches and traces possible layering when declared funds re-enter domestic accounts.
  • Contains verified customer identities, financial profiles, and supporting documentation.
  • Enables investigators to confirm if declared sums match the customer’s legitimate sources of funds.
  • Helps identify potential discrepancies in declared reasons for cross-border cash movements versus actual business or personal profiles.

Provides detailed records of international funds transfers, including amounts, participant institutions, routing details, and settlement processes. Investigators can:

  • Compare electronically transferred funds with declared cash movements to uncover inconsistencies.
  • Detect layering attempts by tracing cross-border flows through multiple jurisdictions.
  • Identify suspicious patterns in cross-border transactions that do not align with legitimate business activities or declared sums.
  • Captures origin, destination, and route details for financial movements.
  • Enables detection of frequent or repeated cross-border trips involving smaller declared amounts (smurfing).
  • Helps aggregate multiple declarations below thresholds that collectively sum to higher illicit totals.

Mitigations

Require in-depth reviews for customers regularly depositing cross-border cash, including verification of original customs records, confirmation of fund origin, and cross-checking declared amounts with travel itineraries or exchange receipts. This heightened scrutiny exposes attempts to inflate or falsify declared sums.

Implement scenario-based rules that cross-check declared cross-border amounts with subsequent deposits, flagging repeated large currency entries inconsistent with typical travel or business patterns. This ensures rapid detection of inflated declared sums, reused customs documents, or contradictions between declared and deposited amounts.

Require immediate CTR filings for large or recurring cross-border cash deposits tied to declared amounts. Mandating full details—such as customs reference numbers and final deposit totals—establishes an audit trail, exposing inconsistencies between physical declarations and actual funds deposited.

Leverage open-source data and border control information to validate the authenticity and frequency of declared cross-border currency entries. Investigate any repeated use of identical customs forms or irregular travel patterns that suggest declarations are being fabricated or inflated.

Continuously re-evaluate customers who frequently declare foreign currency at borders, comparing each declaration against actual deposits and ongoing account activity. Promptly investigate reused declaration records, unexplained fluctuations in declared sums, or inconsistent exchange transactions.

Instruments

IN0051
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  • Criminals physically transport large sums across borders, filing official declarations to appear compliant.
  • They exploit weak or inconsistent verification by over-declaring amounts, thereby ‘legitimizing’ additional illicit funds that never actually crossed the border.
  • Subdividing declared cash into multiple smaller declarations or various currencies helps them evade threshold checks.
  • They reuse or falsify the same declaration records for subsequent deposits or transfers, making it more difficult for authorities to detect discrepancies between physical cash carried and the higher amounts ultimately introduced into the financial system.

Service & Products

  • Criminals break up large declared sums into smaller remittance transactions, staying below reporting thresholds and evading heightened scrutiny.
  • They present customs declaration documents as evidence of lawful origin, even if the actual amount physically imported was lower.
  • By spreading transactions across multiple recipients or locations, perpetrators further complicate investigations into the funds’ illicit source.
  • Criminals present official customs declaration documents as proof of lawful funds, enabling them to convert large amounts of illicit cash into other currencies with minimal scrutiny.
  • Over-declaring the amount upon entry allows them to exchange more than was physically carried, effectively laundering additional illicit funds under the guise of legitimate declarations.
  • By conducting multiple exchanges across different currencies or service providers, criminals further obscure the paper trail.
  • Perpetrators leverage official customs declarations to justify international transfers of funds, asserting these declared amounts represent legitimate capital.
  • Such cross-border transfers complicate AML efforts due to inconsistent coordination among jurisdictions, allowing criminals to obscure the money’s true origin.
  • Re-using or falsifying border declaration records multiple times helps inflate or legitimize additional illicit sums transferred back under the pretense of lawful possessions.

Actors

Criminals exploit money services businesses by presenting official customs declarations as supposed proof of lawful origin for the cash. These businesses:

  • Convert declared currency into other currencies or instruments without suspecting its illicit source.
  • Process multiple smaller exchanges or transfers, allowing perpetrators to avoid triggering threshold-based reporting.
  • Rely on the legitimacy conferred by official declarations, inadvertently facilitating the entry of illicit funds into the financial system.

Illicit operators knowingly employ cross-border currency declarations to legitimize the physical movement of illicit funds. They:

  • Over-declare amounts upon entry, creating official documentation that justifies additional funds not physically transported.
  • Break larger sums into multiple smaller declarations or distribute the money into different currencies (smurfing) to stay below thresholds that trigger heightened checks.
  • Reuse or falsify declaration records to obscure the origin of funds when dealing with financial institutions, leveraging the appearance of lawful cross-border transactions.
AT0064
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Cash couriers physically transport currency across borders on behalf of illicit operators. They:

  • Openly declare large sums to border authorities, leveraging official customs processes to lend an aura of legitimacy to otherwise illicit cash.
  • Potentially coordinate multiple trips or couriers so each declaration remains beneath scrutiny thresholds.
  • Present customs declaration documents when dealing with financial or money services, making the funds appear lawfully introduced.

References

  1. 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

  2. Financial Action Task Force (FATF). (2019, July). Terrorist financing risk assessment guidance. FATF.https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Terrorist-Financing-Risk-Assessment-Guidance.pdf

  3. GAFILAT (Financial Action Task Force of Latin America). (2021). Strategic analysis product on patterns, trends and alerts related to the physical transportation of cash and bearer negotiable instruments in the region. GAFILAT.https://biblioteca.gafilat.org/wp-content/uploads/2024/04/Strategic-Analysis-of-the-Physical-Transportation-of-Cash-and-Bearer-Negotiable-Instruments-BNI-in-the-region.pdf