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Old Oct 23, 2019, 8:29 am
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Money Laundering by Flight Attendants

"Thousands" of dollars recovered. The most startling thing about the article is the low stakes.
I thought you were allowed to bring less than $10,000 into the country without reporting it.

(CNN)Four American Airlines flight attendants were arrested at the Miami International Airport and charged with money laundering after bringing large amounts of cash into the country, police said.

The airline says it's working with law enforcement on their investigation.
The flight attendants were going through a routine customs check Monday during the time of their arrest, according to a Miami-Dade police report.One Customs and Border Patrol Agent was checking Carlos Alberto Munoz-Moyano, who had arrived on an incoming flight from Chile. The agent asked him how much money he was carrying, and Munoz-Moyano said he had $100, the police report said.
He later changed his statement and said he had $9,000, according to the police report.
The agent alerted other agents, who found other attendants from the same fight carrying large amounts of money, the report said; none had a license to transport the cash.
The police report has redacted what the flight attendants admitted to when they were interviewed by a Homeland Security Agent.
Agents found $7,300on flight attendant Miaria Delpilar Roman-Strick and $6,371 on Maria Isabel Wilson-Ossandon, the report said.
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Old Oct 23, 2019, 9:00 am
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Here is a link to the original article: https://www.cnn.com/2019/10/23/us/fl...ami/index.html

The $10K limit is for persons traveling together which under eyes of CBP the flight crew was probably considered. As such, if they have $10,000 or more, they cannot divide the currency between each other to avoid declaring the currency.


Edit: I am stating what the CBP probably did in order to arrest the flight attendants. That is after catching one not being truthful, finding the others each with a large sum of cash, deciding there was a concerted effort to circumvent the $10k limit, and thus arrest them. I am not stating what the CBP did was proper just what mechanism was used for the arrest. The four flight attendants can argue their points in court.

Last edited by FlyingUnderTheRadar; Oct 23, 2019 at 11:11 am
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Old Oct 23, 2019, 9:15 am
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The $10,000 limit is for persons travelling together.




Hmm. So if the Oakland Raiders and their roadies fly on the same plane into the States they have to add all their money together and "report" it if it exceeds the paltry sum of $10,000? Also, since when are flight attendants all considered to be travelling "together" if they have separate families and separate hotel rooms? Something about this story seems kind of fishy.
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Old Oct 23, 2019, 9:43 am
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Originally Posted by FlyingUnderTheRadar
Here is a link to the original article: https://www.cnn.com/2019/10/23/us/fl...ami/index.html

The $10K limit is for persons traveling together which under eyes of CBP the flight crew probably considered. As such, if they have $10,000 or more, they cannot divide the currency between each other to avoid declaring the currency.
The $10k limit triggering a declaration requirement would not easily stick to a group of flight crew members unless and until the crew members are found to have been acting as a group engaged in structuring to get below the declaration trigger amount or of individually having in their possession the trigger amount or more. The CBP seems to believe that the four flight attendants were in on a conspiracy together. Was the conspiracy one of taking iPhones to Chile for dollar sales and then bringing back the cash? If so, why not just declare it instead of engaging in unlawful structuring?

I don’t recall flight crew members having a different cash declaration trigger in the US than the average US-resident tourist returning to the US, but they often have a duty free allowance that is way lower than that applicable to the average American tourist returning to the US from a short trip abroad.

Last edited by GUWonder; Oct 23, 2019 at 9:50 am
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Old Oct 23, 2019, 11:14 am
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Originally Posted by FlyingUnderTheRadar
Here is a link to the original article: https://www.cnn.com/2019/10/23/us/fl...ami/index.html

The $10K limit is for persons traveling together which under eyes of CBP the flight crew probably considered. As such, if they have $10,000 or more, they cannot divide the currency between each other to avoid declaring the currency.
I don't see in either 31 USC § 5316 or FinCEN Form 105 where it there is any default aggregation of travelers involved regarding the $10K limit.

The statutory provisions on structuring do address splitting up the currency among others in order to evade the reporting requirements. So in that sense a group could run afoul of the law if someone was knowingly structuring and the gov't suspected and later could prove such. It sounds like that may have been what happened here (or what CBP thinks happened). THe article states that the first FA to have been checked was Carlos Alberto Munoz-Moyano who responded that he had $100 in cash. The article then says that Munoz-Moyano "later changed his statement" to having $9,000. What happened between those two statements? Presumably CBP found the additional cash in his bags.

CBP then locates the other FAs and finds cash on them as well. Did Munoz-Moyano say something that led CBP to suspect the he wasn't acting alone or was CBP just fishing when it came to the other FAs? The article notes that the police report has redacted what the FAs admitted to when questioned. So it seems we don't have the whole story but there is, as usual, more to it.

This article seems to have a couple more details, indicating that the FAs admitted to smuggling/structuring (for a rather low earning rate supposedly) and that one of the FAs was fingered as the instigator:

https://www.miamiherald.com/news/loc...236533813.html
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Old Oct 23, 2019, 1:40 pm
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The AA forum on FT has a thread about this very same topic.
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