Now Boarding Flight # FinCEN 105

Thu, Mar 10, 2011 - 1:26pm

It started as a typical travel day.

After a restless night, my mind darting about from one thought to the next, the battery-driven mechanical rooster lets loose with its rhythmic beep-beep-beep, announcing it’s time to stop pretending you are asleep, get out of bed, and get on with things.

The requisite hygienic routine, along with a hot mug of French roast and a glug of half-and-half from the complimentary in-room coffee station, gets the brain and the bones revved up for the long journey ahead.

I dress, pack and scan the room for that forgotten item. Before heading to the lobby to catch the airport shuttle, I let my bag dangle from one arm, like a marlin hanging from a scale on a pier, confident that it will meet the Jenny Craig-inspired airline weight limits on checked luggage. Dirty clothes really do weigh more.

“Far out,” I say half out loud while exiting the elevator as the olfactory nerve sends a Starbucks proximity alert to that area of the brain responsible for addiction. Two cups before 10 o’clock is my morning routine. It’s one of my few vices, and I have no intention of giving it up.

Slipping the to-go cup inside an insulating sleeve, I wheel my marlin out to the van, grab a seat, and we’re off.

Next to the inventions of the ATM and deodorant, the self-service check-in kiosk at most airports is a thing of beauty. Relieved, Jenny gives my 44-pound bag the nod.

The next part of the story – the TSA gauntlet – is all too familiar to even the occasional vacation flyer, and I will fast-forward through the personal grumbling.

Once reunited with my shoes, belt, wallet, coat, watch, MacBook and backpack, I amble down to the departure gate.

Part and parcel of the publishing business is the need to meet deadlines, and, as is my nature, I have arrived plenty early for my flight to Frankfurt, Germany.

I notice that the aircraft is already at the gate, the flight is listed on the monitor behind the check-in counter, and the jet bridge is positioned for the boarding process. A little later the catering trucks arrive. So far, so good.

About 70 minutes prior to departure, the flight crew arrives, and soon after the flight attendants begin to flock in, in pairs and trios.

Then something non-routine occurs.

A group of men arrive at the gate and mingle at the boarding door. Two are wearing street clothes, two are airline representatives, and three are Customs and Immigration officials. They are all sporting official-looking ID cards dangling from a lanyard around their necks. They chat for a few minutes, one of the airline reps opens the boarding door, and they all step inside a small room that adjoins the jet bridge. They remain in this area in full view of anyone that can see the glass boarding door.

An announcement is made by the gate agent, the scripted message dutifully read from a hand-held card, informing passengers traveling to Frankfurt about U.S. federal regulations that restrict the amount of cash or monetary instruments that can be transported outside the country without filing a declaration. The form required if you do possess more than 10 grand is FinCEN Form 105 International Transport of Currency or Monetary Instruments.

The announcement is made three times. You are asked to see one of the Customs and Immigration officials available on the jet bridge if you have any questions or are carrying more than $10,000 in cash or monetary instruments.

Wow, I thought, they’re here. No doubt about it, they’re here. Currency controls. No rumor or hearsay, I am witness to the event.

I was seated in the sharp end of the plane – business class – and boarded with the second group of passengers. Every passenger that boarded before me was asked for their passport and if they were carrying more than $10,000 in cash or its equivalent. After I was questioned, as I walked down the jet bridge, I glanced over my shoulder, and everyone boarding behind me was being asked as well.

The set-up was very controlled and calculated; asking the passenger for his passport allowed the officer time to size you up, and time for anyone not proficient in lying to give themselves away with a nervous tic or tell.

We have warned for years about the inevitable arrival of currency controls. Well, they are definitely here, and bureaucratic inertia will only accelerate and expand this trend in motion.

It is not hard to imagine Customs and Border Protection agents conducting similar routine checks at banks at some future point. And as the program expands, law enforcement could also get involved. Being cited for a driving violation may soon include questioning about your finances.

If you have not sent a large portion of your wealth on an overseas vacation, the time to start the process is now. Today, if you follow the rules (and we are not suggesting that you do anything illegal), it is completely legal to carry, transport or wire money out of the U.S. We do not expect that today’s relative ease with which you can transfer money internationally will last for much longer. And do not expect a change in this policy to be announced months in advance of implementation. When a change is made, in all likelihood it will take effect immediately upon its release.

If diversifying wealth out of the dollar and having it reside in another country is on your to-do list, get started today.

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