Will United States Airlines Now Post A Link To FinCEN Form 105 On Their Internet Sites For Passengers Traveling To Cuba?

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Beginning at 6:00 pm on 23 November 2020, absent the services of Denver, Colorado-based Western Union Company (2019 revenues approximately US$5.3 billion) there will be an increase in “mule” traffic on regularly-scheduled commercial airline flights and charter airline flights from the United States to the Republic of Cuba.

A “mule” is an individual who collects United States currency on behalf of third parties and transports it to the Republic of Cuba.

When transporting more than US$10,000.00, a passenger is required to file a report declaring the exact amount of funds to U.S. Customs and Border Protection (CBP) within the U.S. Department of Homeland Security (DHS).  An increasing number of United States-based financial institutions have instituted requirements for customers to also file disclosure forms when obtaining less than US$10,000.00 in currency from their bank branch.  LINK To FinCEN Form 105

Most of the flights operate from Miami International Airport (MIA) to Jose Marti International Airport (HAV).

There had been additional flights from Boston Logan International Airport, Fort Lauderdale-Hollywood International Airport, George Bush Intercontinental Airport (Houston), Hartsfield-Jackson Atlanta International Airport, John F. Kennedy International Airport, Newark Liberty International Airport, and Tampa International Airport. 

Airlines operating schedules have included American Airlines, Delta Air Lines, Jet Blue Airways, Southwest Airlines, and United Airlines. 

Cuba Airline Operations 

  • In December 2019, the Trump administration restricted United States regularly-scheduled commercial flights and authorized charter flights to HAV.  The decision ended regularly-scheduled flights by Delta Air Lines, Jet Blue Airways, and United Airlines to cities including Camaguey, Holguin, Santa Clara, and Santiago de Cuba. 

  • Regularly-scheduled commercial flights from MIA represent the majority of all regularly-scheduled commercial flights from the United States to the Republic of Cuba.  

  • Regularly-scheduled commercial flight and authorized charter flight passengers departing MIA for HAV primarily use Concourses D (American Airlines), E (American Airlines, Swift Air) and J (Swift Air) at MIA. 

  • After a hiatus due to the impact of COVID-19, HAV resumed its international flight operations on 15 November 2020. 

  • On 4 November 2020, Fort Worth, Texas-based American Airlines reported that three flights daily would operate from MIA to HAV. 

Trump Administration Decisions 

The Trump Administration prohibits United States-based companies from engagement with entities controlled by the Revolutionary Armed Forces (FAR) of the Republic of Cuba.  There is no indication the prohibition will be rescinded or revised.  The United States Department of State added to the Cuba Restricted List Republic of Cuba government-operated American International Services (AIS) and Financiera Cimex (Fincimex), a Panama-registered subsidiary of Republic of Cuba government-operated Corporacion Cimex which is a subsidiary of Grupo de Administracion Empresarial S.A. (GAESA) and controlled by the FAR.  Fincimex is the distribution partner in the Republic of Cuba for Western Union Company.