REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Regulation (EU) 2018/1672 of the European Parliament and of the Council of 23 October 2018 on controls on cash entering or leaving the Union and Repealing Regulation (EC) No 1889/2005 pursuant to article 19 of this Regulation
Date: 2025-07-08
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: application of EU law, customs formalities, customs inspection, disclosure of information, exchange of information, external border of the EU, fight against crime, money, money laundering, terrorism financing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.7.2025  COM(2025) 360 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Regulation (EU) 2018/1672 of the European Parliament and of the Council of 23 October 2018 on controls on cash entering or leaving the Union and Repealing Regulation (EC) No 1889/2005 pursuant to article 19 of this Regulation  
 
 
1. INTRODUCTION 

Criminals across Europe are using the financial system in a way that endangers the security of the 
EU and its citizens. There are two main ways in which criminals exploit the financial system. The 
first is by taking the proceeds of crime and re-introducing it to the legitimate economy (money 
laundering). The second is by diverting money from the legitimate economy through the financial 
system to fund criminal activity. In the context of money laundering schemes, cash (1) still features 
prominently today, according to Europol’s latest serious and organised crime threat assessment of 
2025. 

Regulation  (EU)  2018/1672  on  controls  on  cash  entering  or  leaving  the  Union (2)  (the  Cash 
Controls  Regulation)  lays  down  rules  to  protect  the  EU  against  money  laundering  or  terrorist 
financing by fraudulent operators who might attempt to cross EU external borders carrying cash or 
move cash via other means, in order to circumvent the controls of the formal financial system. 

This report presents the feedback gathered by the Commission on the implementation of the Cash 
Controls  Regulation.  It  fulfils  the  obligation  under  Article 19  of  the  Cash  Controls  Regulation, 
which requires the Commission to submit a report to the European Parliament and to the Council 
on the Regulation’s application. 

2. GENERAL BACKGROUND 

2.1.  European  Union  anti-money  laundering  and  counter-terrorist  financing  (AML/CFT) 
legislation and international aspects 

The Cash Controls Regulation lays down controls on cash entering or leaving the EU. It is part of 
the EU anti-money laundering and counter-terrorist financing (AML/CFT) legislative framework 
and complements Directive (EU) 2015/849 (3) and Directive (EU) 2018/1673 (4). 

In addition, the Regulation aims to tackle Recommendation 32 on cash couriers of the Financial 
Action Task Force (FATF). As a member of the FATF, the European Commission is committed to 
implementing the FATF’s recommendations on developing and promoting global policy standards 
on AML/CFT, at both national and international level. 

(1)   For a definition of cash, see Section 3.1. of this report. 

(2)    Regulation  (EU)  2018/1672  of  the  European  Parliament  and  of  the  Council  of  23 October  2018  on 
controls on cash entering or leaving the Union and repealing Regulation (EC) No 1889/2005, OJ L 284, 
12.11.2018, ELI: http://data.europa.eu/eli/reg/2018/1672/OJ. 

(3)    Directive  (EU)   2015/849  of  the  European  Parliament  and  of  the  Council  of  20 May  2015  on  the 
prevention of the use of the financial system for the purposes of money laundering or terrorist financing, 
amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing 
Directive  2005/60/EC  of  the  European  Parliament  and  of  the  Council  and  Commission  Directive 
2006/70/EC, OJ L 141, 5.6.2015, ELI: http://data.europa.eu/eli/dir/2015/849/2024-07-09. 

(4)    Directive  (EU)  2018/1673  of  the  European  Parliament  and  of  the  Council  of  23 October  2018  on 
12.11.2018,  ELI: 
criminal 

law,  OJ  L 

284, 

combating  money 
http://data.europa.eu/eli/dir/2018/1673/OJ. 

laundering 

by 

1 

 
 
 
 
 
 
 
EU legislation on cash controls has been in place since 2005 (5). It was reviewed once in 2018 to 
take account of the development of international norms and the EU AML/CFT framework, but also 
to take stock of the Commission priorities under the 2016 terrorism finance action plan. 

2.2. The cash controls legislation 

The  Cash  Controls  Regulation  fully  entered  in  application  on  3 June  2021  and  was  further 
complemented with: 

–  Commission Implementing Regulation (EU) 2021/776 of 11 May 2021 establishing templates 
for certain forms as well as technical rules for the effective exchange of information under 
Regulation (EU) 2018/1672 of the European Parliament and of the Council on controls on 
cash entering or leaving the Union (6); 

–  Commission Implementing Decision C(2022)1801 of 24 March 2022 laying down measures 
for the uniform application of controls by establishing common cash movements risk criteria 
and standards pursuant to Regulation (EU) 2018/1672 of the European Parliament and of the 
Council  on  controls  on  cash  entering  or  leaving  the  Union  (not  published  in  the  Official 
Journal of the European Union (OJEU) due to its sensitive, non-classified nature). 

2.3. Scope of the report 

According  to  Article 19  of  the  Cash  Controls  Regulation,  by  June  2024,  and  every  five  years 
thereafter, the Commission, on the basis of the information regularly received from the Member 
States, must submit a report to the European Parliament and to the Council on the application of 
that Regulation. 

The present report will address all items under Article 19, namely whether: 

(a) other assets [are] included within the scope of this Regulation; 

(b) the disclosure procedure for unaccompanied cash is effective; 

(c) the threshold for unaccompanied cash [is] reviewed; 

(d) the information flows in accordance with Articles 9 and 10 and the use of the Customs 
Information System (CIS), in particular, are effective or whether there are obstacles to the 
timely and direct exchange of compatible and comparable information between competent 
authorities and with FIUs (7); and 

(e) the penalties introduced by Member States are effective, proportionate and dissuasive 
and in line with the established case-law of the Court of Justice of the European Union 
and whether they have an equivalent deterrent effect across the Union on the infringement 
of this Regulation. 

In accordance with Article 19, the report also includes: 

(5)   Regulation (EC) No 1889/2005 of the European Parliament and of the Council of 26 October 2005 on 
the  Community,  OJ  L309,  25.11.2005,  ELI: 

leaving 

controls  of  cash  entering  or 
http://data.europa.eu/eli/reg/2005/1889/OJ. 

(6)   OJ L 167, 12.5.2021, ELI: http://data.europa.eu/eli/reg_impl/2021/776/OJ. 
(7)  Financial Intelligence Units. 

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(a) a compilation of information received from Member States regarding cash related to 
criminal activities which adversely affect the financial interests of the Union; 

(b) information on exchange of information with third countries. 

This report covers the period from the entry into application of the Regulation on 3 June 2021 until 
2 June 2024 (inclusive). 

This  report  does  not  cover  Commission  Implementing  Decision  C(2022)1801  establishing 
common cash movements risk criteria and standards as it is a sensitive non-classified document 
not published in the OJEU, as mentioned above. 

2.4. Means used to prepare the report 

The present report draws on: 

–  Member States’ responses to an EU survey covering all aspects of the implementation of the 

Cash Controls Regulation; 
information provided by Member States’ customs authorities during the exchanges with the 
Commission, including the meetings of the Cash Controls Expert Group; 
information provided by Commission departments; 
statistical data available in the Customs Information System (CIS) cash module (8);  
information provided by FIUs (9). 

– 

– 
– 
– 

3. CORE ELEMENTS OF THE CASH CONTROLS REGULATION 

3.1. The definition of cash 

‘Cash’ is defined as comprising four categories (10): 

– 
– 

– 

– 

currency (banknotes and coins); 
bearer-negotiable instruments (e.g. traveller’s cheques, cheques, promissory notes or money 
orders); 
commodities used as highly-liquid stores of value as listed in point 1 of Annex I of the Cash 
Controls Regulation (i.e. coins with a gold content of at least 90% and bullion such as bars, 
nuggets or clumps with a gold content of at least 99.5%); 
prepaid cards which are non-nominal cards that store or provide access to monetary value or 
funds (11). 

(8)  CIS also includes data on cases related to the United Kingdom with respect to Northern Ireland, as the 
Cash Controls Regulation continues to apply in the UK pursuant to Article 5 and Annex 2 of the Protocol 
on Ireland/Northern Ireland of the Windsor Framework. 

(9)  An obligation to report any suspicious transaction to FIUs has been laid down by Council Directive 
91/308/EEC. FIUs were set up as hubs to assess such transactions, interact with their counterparts in 
other countries and, where required, contact judicial authorities. 

(10)  Article 2(1)(a) of Regulation (EU) 2018/1672. 

(11)  Although included in the definition of cash set out in the Cash Controls Regulation, prepaid cards are 
currently not subject to the rules on cash controls movements due to the fact that the relevant point in 
Annex I of the Cash Controls Regulation mentions: P.M. (pro memoria). 

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3.2. The obligation to declare cash (cash declaration) 

An obligation to declare is imposed on natural persons entering or leaving the EU (12) carrying 
cash  of  a  value  of  EUR 10 000  or  more  on  their  person,  in  their  luggage,  or  in  the  means  of 
transport. Its level has been set so as to not restrict free movement unduly or overburden citizens 
and authorities with administrative formalities. 

The carriers concerned are required to make the cash available to the competent authorities for 
inspection. They must provide the following information, either in writing or electronically: 

– 

– 

full personal details, such as name, nationality and date of birth of the carrier, the owner and 
the intended recipient of the cash; 
value and nature of the cash, its origin, its intended use and the method of transport. 

The definition of ‘carrier’ excludes those carriers who undertake the professional conveyance of 
goods or people (13). 

3.3. The obligation to declare unaccompanied cash (disclosure declaration) 

For movements of unaccompanied cash (i.e. cash entering or leaving the EU in postal packages, 
courier shipments, unaccompanied luggage or containerised cargo), the competent authorities may 
require the sender or the recipient, or a representative thereof, to make a disclosure declaration, 
systematically or on a case-by-case basis, in accordance with national procedures. The obligation 
to disclose unaccompanied cash is subject to a EUR 10 000 threshold, the same as the one applied 
to persons carrying cash. 

3.4. Sub-threshold amounts 

The Cash Controls Regulation  also provides for the recording of information on movements of 
cash below the set threshold, if there are indications of criminal activity in these movements (14). 
This  information  is  shared  with  the  respective  FIU  and  with  the  competent  authorities  in  other 
Member States. 

3.5. Capacity to detain cash temporarily for further investigations 

The competent authorities are entitled to detain cash temporarily (15) in certain circumstances, 
and in accordance with the conditions laid down in national law: 

– 
– 

firstly, where the obligation to declare or to disclose cash has not been met; and 
secondly,  where  there  are  indications  of  criminal  activity,  irrespective  of  the  amount  or 
whether the cash is accompanied or unaccompanied. 

(12) Article 3 of Regulation (EU) 2018/1672. 

(13) Article 2(1)(h) of Regulation (EU) 2018/1672. 

(14) Article 6 of Regulation (EU) 2018/1672. 

(15) Article 7 of Regulation (EU) 2018/1672. 

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The period of detention is limited to the absolute minimum time that other competent authorities 
need to determine whether there are grounds for further actions, such as investigations or seizure 
of the cash based on other legal instruments. This period is set by the Cash Controls Regulation 
and  cannot  exceed  30  days.  It  can  be  extended  to  a  maximum  of  90  days  in  specific  and  duly 
assessed cases. 

3.6. Exchange of information between competent authorities and with the Commission 

To ensure effective cooperation, the Cash Controls Regulation provides for the exchange between 
Member  States’  competent  authorities  of  the  following  information:  (i)  ex  officio 
declarations (16);  (ii)  sub-threshold  amount  cases;  (iii)  declarations  and  disclosure  declarations, 
where there are indications that the cash is related to criminal activity; and (iv) anonymised risk 
information and risk analysis results. 

Moreover,  where  there  are  indications  that  the  cash  is  related  to  criminal  activity  which  could 
adversely affect the financial interests of the EU, the relevant information must also be shared with 
the Commission, the European Public Prosecutor’s Office and Europol where they are competent 
to act. 

A Specific module has been developed within CIS for implementing the Cash Controls Regulation 
and to allow for exchange of information. This module is managed by the European Anti-Fraud 
Office (OLAF). 

3.7. Information to be sent to the Financial Intelligence Unit (FIU) 

The competent authorities that collect information pursuant to the Cash Controls Regulation must 
send it in a timely manner to the national FIU to enable further analysis and so that the information 
can be compared with other data as provided for in Directive (EU) 2015/849 (17). 

3.8. Penalties 

To  encourage  compliance  and  deter  circumvention,  Article 14  of  Regulation  (EU)  2018/1672 
requires Member States to introduce penalties for non-compliance with the obligations to declare 
or  disclose  cash.  Those  penalties  should  not  take  into  account  the  potential  criminal  activity 
associated with the cash, which may be the object of further investigation and measures that fall 
outside the scope of the Regulation (18). 

Those penalties should be effective, proportionate and dissuasive, and should not go beyond what 
is  required  to  encourage  compliance.  Penalties  introduced  by  Member  States  should  have  an 
equivalent deterrent effect across the EU on the infringement of the Cash Controls Regulation. 

(16)  i.e. in case where the obligation to declare accompanied cash under Article 3 or the obligation to disclose 
unaccompanied  cash  under  Article 4  has  not  been  fulfilled,  the  competent  authorities  compose,  in 
writing or in an electronic form, an ex officio declaration containing to the extent possible the necessary 
details. 

(17) Article 9 of Regulation (EU) 2018/1672. 

(18) Recital 35 of Regulation (EU) 2018/1672. 

5 

 
 
 
 
 
 
 
 
3.9. A harmonised declaration form 

To  ensure  the  uniform  application  of  controls  and  the  efficient  processing,  transmission  and 
analysis by competent authorities of the declarations, Commission Implementing Regulation (EU) 
2021/776 lays down templates for: 

– 
– 
– 

– 

the cash declaration and the relevant additional sheet; 
the cash disclosure declaration and the relevant additional sheet; 
the  form  for  official  use  (to  be  filled  in  and  attached  to  the  ex  officio  declarations  under 
Article 5(3)), recoding of information under Article 6(1) and (2) and declarations obtained 
under Articles 3 and 4 where there are indications of criminal activity; 
the transmission of anonymised risk information and risk analysis results. 

3.10. Information campaigns 

To raise awareness  about the obligations laid down in the Cash Controls Regulation, Member 
States, in cooperation with the Commission, must develop appropriate information materials on 
the obligation to declare or disclose cash (19). 

3.11. Main novelties laid down by Regulation (EU) 2018/1672 

The main novelties of the Cash Controls Regulation are: 

• 

• 

• 
• 

• 

an extended definition of cash to cover also commodities used as highly-liquid stores of 
value (gold) and prepaid cards for both accompanied and unaccompanied cash (in freight and 
postal shipments); 
an  increase  in  the  sharing  of  information  between  competent  authorities  and  between 
competent authorities and FIUs; 
provision for the IT system to be used for such exchanges; 
the powers granted to competent authorities to act upon lower amounts of cash if they suspect 
a link with criminal activities; 
the  powers  granted  to  competent  authorities  to  require  the  sender  or  the  recipient  (or  a 
representative  thereof)  to  make  a  disclosure  declaration  for  cash  entering  or  leaving  the 
Union in postal packages, courier shipments, unaccompanied luggage, or containerised cargo 
(movements of unaccompanied cash). 

4.  ASSESSMENT  ON  THE  IMPLEMENTATION  OF  THE  CASH  CONTROLS 
REGULATION BY MEMBER STATES 

4.1. Information campaigns 

(19) Article 8 of Regulation (EU) 2018/1672. 

6 

 
 
 
 
 
 
 
 
 
 
 
 
 
The Commission, in cooperation with the Member States, organised a large information campaign 
throughout the European Union to support the implementation of the Cash Controls Regulation 
and to inform the EU public and travellers into the EU about their obligations. 

The Commission made available dedicated campaign materials to all the Member States, including 
factsheets, infographics, posters and short films subtitled in the relevant language. All the materials 
were translated into 30 languages (20) to ensure wide coverage (21). 

4.2. Accompanied cash 

310 042 cash declarations were filed during the period covered by the present report. 23 097 cases 
with infractions were notified in CIS+ Cash (i.e. cases where either no declaration was made, or 
the  information  provided  was  incomplete  or  incorrect  or  there  were  indications  that  cash  was 
related to criminal activity). 

The declaration procedure for accompanied cash has been implemented by all the Member States 
according to the statistical results presented in Chart 2 in Annex A. For the period between 2022 
and 2023, Poland, Germany and France represented 57% of the reported accompanied cash cases. 

According to the results of the survey, Member States consider the cash declaration procedure to 
be effective and give it a positive assessment (65% rated it as very good, 30% as good, and 5% as 
fair). 

Most respondents agreed on the following points. 

• 

• 
• 

The Cash Controls Regulation gives customs authorities the power to stop and detain cash 
where there are indications that that cash is related to criminal activities. 
The declaration procedure is reliable in detecting cross-border movements of cash. 
The declaration procedure allows customs authorities to gather information to identify illicit 
cash movements. The wide range of information collected is particularly useful for subsequent 
investigations. 

However,  two  Member  States  remarked  that  the  procedure  could  be  improved;  one  of  them 
mentioned specifically the poor quality of the data provided by carriers in their cash declarations. 

4.3. Unaccompanied cash 

6 532 cash disclosure declarations were filed  during the period covered by this report, and 102 
infractions related to this procedure were notified in CIS+ Cash. There were 6 Member States that 
did not record any cash disclosure declarations for the period between 2022 and 2023 (Belgium, 
Ireland, Malta, Slovenia, Finland, Sweden). 

Most of the Member States which responded to the survey had a neutral-to-positive view of the 
unaccompanied  cash  disclosure  procedure  (6  rated  it  as  good,  11  as  fair  and  3  as  poor).  They 
consider that it allows for better control of cash movements and that it functions efficiently. Some 

(20)  AR, BG, CH, CS, DA, DE, EL, EN, ES, ET, FI, FR, GA, HI, HR, HU, IT, JP, LT, LV, MT, NL, PL, 

PT, RO, RU, SE, SK, SL, TR. 

(21)  See, for example, the factsheet Get up to speed with the latest cash control rules!. 

7 

 
 
 
 
 
 
 
Member States expressed the view that the procedure is effective as it is based on risk analysis 
rather than on the mandatory submission of the cash disclosure declaration. 

Nonetheless, Member States expressed the following three reservations. 

– 
– 

– 

The unaccompanied cash disclosure procedure is administratively complex; 
The  30-day  deadline  to  submit  the  disclosure  declaration  upon  request  by  the  customs 
authorities is too long; 
The risk analysis needs to be fine-tuned to be effective. 

One Member State observed that the fact that the disclosure of unaccompanied cash is only upon 
request and not mandatory in all cases makes customs controls more challenging. That Member 
State  also  added  that,  in  its  view,  the  figures  from  international  actions  show  that  the  risk  of 
unaccompanied  transport  of  cash  in  postal,  parcel  and  courier  shipments  is  lower  than  initially 
assumed. 

4.4. Use of CIS Cash by competent authorities 

Competent authorities send the relevant information to be recorded in CIS in the following manner: 

(a) by manually entering the information via the CIS user web interface; or 

(b) by exporting the information from their national system(s) and importing it into CIS using the 
CIS XML data format; or 

(c) by connecting their national system(s) directly to CIS via a system-to-system interface provided 
by CIS. 

11 Member States’ customs administrations have connected their national systems directly to CIS 
via a system-to-system interface provided by CIS (Belgium, Bulgaria,  Estonia, Greece, France, 
Latvia, Malta, Austria, Poland, Portugal, Sweden). Two Member States (Czechia and Germany), 
although having been granted access via this system-to-system interface, have not used the system 
so far. Indeed, Germany stated that it is currently using an Excel file developed at federal level to 
report cash data. Nevertheless, automatic access is currently being developed by Germany. Czechia 
responded that the connection between its national system and CIS was not yet available at the time 
of the survey. 

Concerning the  data  exchanges through  CIS,  the  Member  States that  participated  in  the  survey 
indicated their generally positive experience with the exchange of data (see Chart 4 in Annex B). 
They consider  the  CIS+ Cash module as an  ‘easy to use system’, which allows for the smooth 
processing  of  data.  One  Member  State  stated  that  the  CIS+  Cash  module  is  a  major  source  of 
information for identifying and analysing suspected cases of money laundering. 

Nevertheless,  some  Member  States  mentioned  that  they  had  encountered  challenges  when 
transferring information from their national systems to CIS. Two Member States pointed out that 
when they encounter infringements, the data have to be manually entered twice instead of being 
transferred automatically from the CIS+ Cash module to the CIS+ Fraud  module. The Commission 
is aware of this issue which is impeding the implementation of the ‘one seizure/one report’ concept. 
The difficulty stems from the fact that the two modules are based on different legal bases. Efforts 
to resolve it are underway. 

Moreover,  three  Member  States  (Spain,  Italy  and  Slovenia)  still  encounter  difficulties  with  the 
direct  transmission  of  specific  information  to  the  CIS+  Cash  module,  due  to  internal  technical 
issues. All three reported that they are working towards finding a solution. 

8 

 
 
 
4.5. FIU access to data 

The  survey  showed  that  even  though  the  Cash  Controls  Regulation  clearly  provides  that  the 
transmission of information from national FIUs must be performed via the CIS+ Cash module (22), 
not all Member State FIUs have access to it yet. Indeed, only 20 Member States had access at the 
time of the survey. 

Of the Member States FIUs with no access to the CIS+ Cash module: 
– 

3 Member States explained they were currently establishing the connection with the CIS+ 
Cash module; 
1 Member State explained that, according to its national legislation, its customs administration 
shares information under the Cash Controls Regulation with the FIU through a national tool; 
1 Member State explained that due to technical issues, the national FIU is unable to access 
CIS data. 

– 

– 

4.6. Penalties 

Member States must clearly differentiate between the penalties imposed solely for the failure to 
declare or disclose cash under the Cash Controls Regulation and the penalties they may impose for 
criminal activities. All Member States have put in place penalties for failure to comply with the 
obligation to declare accompanied cash or the obligation to disclose unaccompanied cash. 

Under the different national legislation, a variety of penalties have been put in place. Some Member 
States (Belgium, Czechia, Denmark, Germany, Greece, Spain, France, Croatia, Italy, Luxembourg, 
Hungary, Malta, Austria, Poland, Romania, Slovenia, Slovakia, Finland, Sweden) have set only 
administrative  penalties,  without  imposing  criminal  penalties  (see  Table  1  in  Annex  B).  The 
administrative penalties consist of: 

– 

an amount to be seized, with a minimum and maximum level set; 

and/or 

– 

a fine, with a minimum and maximum level set; 

and/or 

– 

a  set  percentage  of  the  amount  over  EUR 10 000  to  be  seized,  under  specific  conditions 
provided in the Cash Controls Regulation; 

and/or 

– 

a fine, with the amount depending on the person’s legal category or status. 

(22)  Article 9 of Regulation (EU) 2018/1672 provides that competent authorities must send information   on 
cash declarations, disclosure declarations, ex officio declarations and sub-threshold amounts suspected 
to be related to criminal activity to FIUs through the cash module available in CIS. 

9 

 
 
 
 
 
 
 
 
 
 
Bulgaria,  Estonia,  Latvia,  Lithuania,  Netherlands,  and  Portugal  impose  both  criminal  and 
administrative penalties. Two Member States (Ireland and Cyprus) impose only criminal penalties. 

4.7. Exchanges of information with non-EU countries 

Member States or the Commission may, under mutual administrative assistance, send the following 
information to a non-EU country, subject to the written authorisation of the competent authority 
which  originally  obtained  the  information,  provided  that  such  transmission  complies  with  the 
relevant national and EU law on the transfer of personal data to non-EU countries: 

(a) ex officio declarations composed under Article 5(3); 

(b) information obtained under Article 6; 

(c) declarations obtained under Article 3 or 4, where there are indications that the cash is related to 
money laundering or terrorist financing. 

Moreover,  any  such  transmission  of  information  by  Member  States  must  be  notified  to  the 
Commission. 

According to the survey, a total of 85 exchanges of information with non-EU countries were carried 
out by 7 Member States since the entry into application of the Cash Controls Regulation. Over 90% 
of the exchanges were with Ukraine and the United-Kingdom. A smaller number of exchanges 
were held with Kazakhstan, Türkiye, and the United-States - see Chart 5 in Annex B. 

4.8. Cash related to criminal activities which adversely affect the financial interests of the EU 

Under the Cash Controls Regulation, where there are indications that the cash is related to criminal 
activity which could adversely affect the financial interests of the EU, the information recorded by 
the  competent  authorities,  is  made  available  to  the  Commission,  to  the  European  Public 
Prosecutor’s Office and to Europol, where they are respectively competent to act, further to the 
competent authorities of other Member States. The financial interests of the EU are ‘all revenues, 
expenditures and assets covered by, acquired through, or due to the Union budget and the budgets 
of the institutions, bodies, offices and agencies established under the Treaties and budgets managed 
and monitored by them’ (23). 

14 Member States have reported 23 such cases to the Commission for the reporting period. All the 
cases  concern  accompanied  cash  and  are  divided  almost  equally  between  cases  involving  cash 
entering the EU (11 cases) and cases of cash leaving the EU (12 cases). 

4.9. Improvements needed in the implementation of certain measures by Member States   

•  Some Member State FIUs still do not have access to  the  CIS+ Cash module or are not 
using  it  to  transmit  the  relevant  information  This  situation  raises  some  concerns  as  it 
represents  non-compliance  with  the  legislation  and  its  objective,  as  the  exchange  of 

(23)  Article 2(3)  of  Council  Regulation  (EU)  2017/1939  of  12 October  2017  implementing  enhanced 
cooperation on the establishment of the European Public Prosecutor’s Office (‘the EPPO’), OJ L 283, 
31.10.2017. 

10 

 
 
 
 
 
 
 
 
information is being done outside the legislative framework provided for. The Commission 
has  reminded Member  States  on  multiple  occasions  of  the  requirement  to  comply  with 
Article 9 of Regulation (EU) 2018/1672. 

•  Regarding the sanctions, the latest mutual evaluation reports of the FATF, some Member 
States’  sanctions  are  not  sufficiently  dissuasive.  In  this  respect,  the  European  Court  of 
Justice  (ECJ),  has  examined  the  national  sanction  mechanisms  adopted  for  the 
implementation  of Article 9  of  Regulation  (EC)  No 1889/2005.  The  opposite  problem, 
namely  excessive  sanctions,  is  also  a  concern. According  to  its  judgment  in  Case  C-
255/14 (24) the ECJ considered that a fine equivalent to 60% of the amount of undeclared 
cash above EUR 50 000 does not seem to be proportionate as such a fine goes beyond what 
is necessary in order to ensure compliance with that obligation and the fulfilment of the 
objectives pursued by that Regulation. Member States should take into account this case 
law as well as the mutual evaluation reports of the FATF. 

•  Member  States  have  notified  the  Commission  of  their  exchange  of  information  with         
non-EU countries only recently, following a specific request from the Commission. The 
Commission  has  reminded  Member  States  on  multiple  occasions  of  their  obligation  to 
notify  any  exchange  of  information  with  a  non-EU  country  immediately.  To  facilitate 
notifications from Member States, the Commission has prepared and shared a common 
template that can be used on a voluntary basis; this is already being used by some Member 
States. 

•  Concerning  the  mandatory  reporting  on  cases  that  could  adversely  affect  the  financial 
interest of the Union, the information reported by Member States was either incorrect or 
incomplete. The reporting made by Member States of those cases needs to be improved.  

5. ASSESSMENT OF THE NEED TO AMEND THE CASH CONTROLS REGULATION 

5.1. Scope: analysis of other assets to be potentially included 

5.1.1. Results of the survey on the definition of cash 

The power to adopt delegated acts to amend Annex I has been delegated to the Commission. This 
is for two reasons, namely: (i) to promptly adapt to future changes of the FATF’s international 
standards; and (ii) to prevent the circumvention of the Regulation through reliance on commodities 
used as highly liquid stores of value or on prepaid cards.  As part of the survey, Member States 
were asked about the merits of including other assets within the scope of the Regulation. 14 of the 
20 Member States that completed the survey replied that the list of assets currently covered by the 
definition is sufficient. However, some Member States made suggestions for amendments to the 
list (see chart  6 in Annex B). These suggested amendments are set out in the five bullet points 
below. 

– 

4 Member States proposed to add prepaid cards. 

(24)  Judgment  of  the  Court  of  Justice  of  16 July  2015,  Robert  Michal  Chmielewski  v  Nemzeti  Adó-  és 
Vámhivatal  Dél-alföldi  Regionális  Vám-  és  Pénzügyőri  Főigazgatósága,  Case  C-255/14, 
ECLI:EU:C:2015:475. 

11 

 
 
 
 
 
 
– 

– 
– 

– 

6 Member States proposed to add  other commodities used as highly liquid stores of value 
such as precious stones, precious metals and alloys, as well as high-value ‘luxury goods’ such 
as wristwatches, jewellery, or precious metals (e.g. platinum) and stones (e.g. diamonds). 
1 Member State proposed to add cryptocurrencies (25). 
1 Member State suggested the inclusion of silver/bronze with the same conditions currently 
applicable for gold content. 
2 Member States suggested that the condition that limits the application of the Regulation to 
coins and bullion with a gold content above a specific percentage should be removed, and that 
the value of gold should be used instead as the only relevant condition (equal to or above 
EUR 10 000). 

One  Member  State  stated  that  adding  prepaid  cards  could  help  to identify  and  fight smuggling 
trends. However, according to that Member State, such an addition to Annex I should only be made 
after proper consultation among the 27 Member States and clear guidelines developed at EU level. 

On high-value items, one Member State stated that such items also facilitate the movement of illicit 
funds across borders as they can be used as a substitute for currency. Nevertheless, there has been 
no dedicated study or analysis of the potential relevance of customs checks under the Cash Controls 
Regulation on this type of fraud. 

5.1.2. Analysis on prepaid cards and commodities used as highly-liquid stores of value 

(a) Analysis by the Commission and Europol 

The Commission’s view is that there is no clear evidence that the definition of cash needs to be 
amended. This view is based on the work done in the context of the supranational risk assessment 
on the risk of money laundering and terrorist financing affecting the single market and relating to 
cross-border activities. 

According to Europol, prepaid cards are used to commit a variety of economic and financial crimes, 
including the financing of terrorism. The threat mostly stems from ‘open loop’ prepaid cards, which 
are sold on the internet, at post offices and local stores and which can be used as normal debit or 
credit  cards.  Europol  considers  prepaid  cards  as  high-risk  products  as  they  can  be  used 
anonymously online or in offshore jurisdictions to make payments in the EU. Furthermore, there 
are no legal limits to the number of cards that a person can purchase or to who is eligible to purchase 
a card. 

The European Financial and Economic Crime Threat Assessment 2023 (26) gives two examples of 
the use of prepaid cards for illicit purposes. 

In  the  first  example,  prepaid  cards  are  used  to  commit  romance  fraud.  In  the  second  example, 
together  with  crypto  vouchers,  prepaid  cards  are  used  for  channelling  criminal  proceeds  into 
cryptocurrency gambling platforms hosted in non-EU jurisdictions where transactions are hard to 
trace. 

(25)  Recital 13 of Regulation (EU) 2018/1672: ‘Despite the high level of risk posed by virtual currencies, as 
evidenced  in  the  Commission’s  report  of  26 June  2017  on  the  assessment  of  the  risks  of  money 
laundering and terrorist financing affecting the  internal market and relating to cross-border activities, 
customs authorities do not have competence to monitor them’. 

(26)  See The Other Side of the Coin: An Analysis of Financial and Economic Crime | Europol. 

12 

 
 
 
 
 
 
 
Despite  prepaid  cards  being  known  as  a  high-risk  payment  method  in  the  context  of  money 
laundering, the Commission and Europol did not report any cases of illicit use of prepaid cards 
involving cross-border physical movement of persons or transport by couriers or parcels. 

(b) Analysis by Member States’ FIUs 

Member  States’  FIUs  were  also  asked  whether  there  was  evidence  that  prepaid  cards  or 
commodities  used  as  highly-liquid  stores  of  value  (excluding coins  with at least  90%  gold  and 
bullion with at least 99.5% gold) are extensively used for money laundering. If the FIUs did indeed 
believe there was such evidence, they were asked what sort of evidence they had found and for 
which types of prepaid cards and commodities. 

Nine Member State FIUs provided responses. Based on their replies, there is no clear evidence that 
prepaid cards are used extensively for money laundering, and in particular in the context of persons 
entering or leaving the EU. Furthermore, they said that in practice, it is difficult to distinguish a 
prepaid card from other types of debit or credit cards. 

Regarding commodities used as highly-liquid stores of value, the FIUs noted that travellers into 
the EU sometimes fail to declare high-value items such as luxury watches, jewellery, diamonds 
and crypto currency ledger wallets. This is done to avoid paying duties and value added taxes at 
import and constitutes tax evasion, which is different from money laundering. 

Therefore, a thorough evaluation of the merits of including these types of assets in Annex I, keeping 
in mind customs control capacities, should be conducted. 

5.2. Threshold for unaccompanied cash 

The  survey  also  asked  Member  States  whether  they  considered  the  financial  threshold  of 
EUR 10 000 for unaccompanied cash as suitable (see chart 7 in Annex B). 

From the 20 Member States participating in the survey, only 14 provided a reply to this question. 
95%  of  them  considered  that  the  threshold  was  appropriate  and  therefore  did  not  need  to  be 
reviewed. 

They  also  noted that the threshold  is  well  known  to all  counterparts  and  stressed  that, for  cash 
amounts under the threshold, the Cash Controls Regulation sets out the necessary provisions for 
recording relevant information and detaining the cash for further investigation if there are signs of 
criminal activity. 

There was, therefore, a general agreement to maintain the current threshold. 

6. CONCLUSION 

Based on the results of the survey and on the other information provided by Member States and 
Commission’s  departments,  the  Cash  Controls  Regulation  performs  efficiently  to  achieve  its 
objectives. 

Member States perceive it as an important legal instrument for controlling the physical movement 
of cash at the EU’s external borders and combating money laundering. 

13 

 
 
 
 
 
 
 
Information  flows  take  place  via  the  CIS+  Cash  Module,  and  comparable  information  is  being 
directly  exchanged  between  the  competent  authorities  and  with  FIUs  in  a  timely  manner. 
Nevertheless, there  is still room for improvement related to the use of the  CIS system in some 
Member States. 

The newly introduced disclosure procedure for unaccompanied cash performs sufficiently well. 

There is no need for the moment to revise the threshold or to include other assets in Annex I of the 
Cash Controls Regulation. The Commission is closely monitoring new trends in money laundering 
and terrorist financing, and the possible use of other commodities used as highly-liquid stores of 
value and of prepaid cards as a means to circumvent the obligation to declare. This first assessment 
does not show any need to amend the current framework. 

14 

 
 
 
ANNEX  A  -  ANNUAL  STATISTICS  ON  ACCOMPANIED  AND  UNACCOMPANIED 
CASH CASES 

The following cash-controls charts are based on: 

- data extracted from the CIS+ Cash module at the time of the survey, 

-  data  communicated  by  Member  States  that  are  still  encountering  difficulties  with  the  direct 
transmission of specific information to the CIS+ Cash module due to internal technical issues. 

They cover the periods between 1/1/2022-31/12/2023 (inclusive). 

Chart 1 presents the total number of cases of cash handled at EU borders. For the reference period 
(1/1/2022-31/12/2023), 226 796 cases were identified by the competent authorities empowered to 
implement the Cash Controls Regulation. This includes cases with and without infraction. 

60.000

50.000

40.000

30.000

20.000

10.000

0

Chart 1: Total number of cases per Member States

48.097

42.814

28.257

24.121

23.974

2.942 2.778

1.276 469

1.494 357

3.183

3.660

1.890

3.975

4.044

156

666

7.889

4885

5.355

1.574

144

932 1.002 663

10.199

BE BG CZ DK DE EE IE EL ES FR HR IT CY LV LT LU HU MT NL AT PL PT RO SI SK FI SE

Chart 2 and Chart 3 show the total number of cases per Member State for accompanied cash (Chart 
2) and unaccompanied cash (Chart 3) for the reference period (1/1/2022-31/12/2023). 

60.000

50.000

40.000

30.000

20.000

10.000

0

Chart 2: Total number of accompanied cash cases

48.089

42.488

28.255

20.775

23.823

10.182

2.942 2.713

1.275 467

1.082 357

2.999

3.647

1.839

3.881

3.870

119

666

7.887

4.883

5.332

1.525

144

931 1.002 663

BE BG CZ DK DE EE IE EL ES FR HR IT CY LV LT LU HU MT NL AT PL PT RO SI SK FI SE

15 

 
 
 
 
 
 
 
Chart 3: Total number of unaccompnied cash cases

3.346

65

0

1

2

8

0

17

2

184

151

13

51

94

37

174

0

2

2

49

23

0

1

0

0

412

326

BE BG CZ DK DE EE IE EL ES FR HR IT CY LV LT LU HU MT NL AT PL PT RO SI SK FI

SE

4000

3500

3000

2500

2000

1500

1000

500

0

There  is  a  large  difference  between  the  total  number  of  accompanied  cash  cases  (221  836), 
including with infractions) and the total number of unaccompanied cash cases (4 960 including 
with infractions).  

The Commission publishes annually statistical data in accordance with Article 18 of Regulation 
(EU) 2018/1672 on controls on cash entering or leaving the EU. These reports can be consulted on 
TAXUD’s  website,  where  general  information  on  cash  controls  can  also  be  found:  EU  Cash 
Controls - European Commission (europa.eu). 

16 

 
 
 
 
 
ANNEX B - ANSWERS TO THE SURVEY 

The charts below represent a selection of the responses provided by Member States.  

Chart 4 shows the results of the assessment made by the Member States that took part in the survey.  
The assessment shows how Member States viewed the implementation of Articles 9 and 10 of the 
Cash Controls Regulation. Generally, Member States had a positive experience with the exchange 
of data through the CIS+ Cash module. Only a few of them rated specific aspects of their experience 
with the CIS+ Cash module as poor or very poor. 

Chart 4: use of CIS+ CASH (articles 9 and 10 of the cash controls 
regulation)

14

12

10

8

6

4

2

0

A

r
t
9

i

-
T
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D

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-

C
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-

C
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Very good

Good

Fair

Poor

Very poor

Chart 5 shows the number of information exchanges with non-EU countries on cases related to 
cash. Most of the exchanges of information between Member States and non-EU countries based 
on Article 11 were with the United Kingdom, Ukraine and Russia. A few exchanges with Türkiye, 
the United States, the United Arab Emirates and Kazakhstan were also reported (only 8.23% on 
the total exchanges with non-EU countries). 

35

30

25

20

15

10

5

0

Chart 5: Exchanges of information with non-EU countries 

UK; 33

RU; 23

UA; 22

KZ; 1

TR; 3

AE; 2

US; 1

KZ

RU

TR

UA

UK

AE

US

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 1 summarises the different penalty systems established by Member States to comply with 
Article 14  of  the  Cash  Controls  Regulation.  Most  of  the  Member  States  apply  administrative 
penalties. 

Table 1: Member States’ penalty systems under the Cash Control Regulation 

Penalties 

Member States 

Type of penalties 

Administrative 

BE,  CZ,  DK,  DE,  EL, 
ES,  FR,  HR,  IT,  LU, 
HU, MT, AT, PL, RO, 
SI, SK, FI, SE 

• 

seizure  of  a  specific  amount,  with  a 
minimum and/or maximum amount set 

and/or 

• 

fine  imposed,  with  a  minimum  and/or 
maximum amount set 

and/or 

• 

seizure of the amount above EUR 10 000, 
under certain conditions 

and/or 

• 

a  percentage  of  the  total  amount  of  the 
the  amount 
undeclared  cash  or  of 
exceeding the threshold 

and/or 

• 

fine,  with  the  amount  depending  on  the 
person’s 
(legal 
person,  sole  proprietor  or  self-employed 
individual, natural person) 

category/status 

legal 

Administrative 
and criminal  

BG,  EE,  LV,  LT,  NL, 
PT 

Criminal 

CY, IE 

•  percentage  of  the  value  of  non-declared 
cash, or a fine, or an amount seized (with 
minimum and/or maximum limits set) 

and/or 

imprisonment, 
circumstances 

depending 

on 

the 

imprisonment if the obligation to declare is 
not fulfilled 

• 

• 

or 

• 

a fine 

Chart 6 summarises the proposals made by Member States on the need to amend Annex I of the 
Cash Controls Regulation. Among the 14 Member States that completed the survey, 43% support 
the proposal to add other commodities used as highly-liquid stores of value and 29% support the 
proposal to add prepaid cards. 

18 

 
 
Chart 6: Proposals on modifying Annex I

7%

14%

29%

7%

43%

Add prepaid cards

Add additional commodities used as
highly liquid store value

Add silver and bronze with % of
content

Remove conditions applicable on
gold

Add cryptocurrencies

Chart 7 shows the Member States’ responses to the survey on the EUR 10 000 threshold set out in 
the Cash Controls Regulation. There is a general agreement that the current threshold is effective 
and should remain the same (95% positive answers). 

Chart 7: Member States' assessment of the current threshold

5%

95%

The threshold should remain at EUR
10 000

It should be less than EUR 10 000

19