Is a financial institution required to fill out a FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments if we know a customer is taking money out of the United States? I have read the instructions and I am interpreting that we are not required to fill it out. But our examiners are requesting our copies of this forms if we have any.

Click here and scroll down to Admin Ruling 88-2. Print copies for your friends.

The obligation to file the CMIR is solely on the person who transports, mails, ships or receives, or causes or attempts to transport, mail, ship or receive. No other person is under any obligation to file a CMIR.

Due to its age, this resource does not mention the possibility that you might consider a SAR filing if you become aware that your customer is not properly reporting the transactions.