United States v. Krikor Baghdassar Tatoyan, A/K/A Krikor Tatoyan, United States of America v. Zenda Bedros Tatoyan, A/K/A Zenda Tatoyan

We examine the long-standing requirements surrounding the personal export of cash from the United States, the more recently enacted bulk cash smuggling prohibitions, and the ever-elusive requirement of willfulness. Here, as in many other areas, honesty remains the best policy.

FACTS AND PROCEDURAL HISTORY

As they were about to board a flight to Paris at Los Angeles International Airport, Krikor and Zenda Tatoyan (“the Ta-toyans”) were stopped by United States Customs Inspector Chung J. Lou (“Inspector Lou”), who was conducting currency enforcement examinations of passengers on that flight. At the time, Krikor had $8,000 cash in his pants pocket and $17,601 cash in two pouches hanging around his neck underneath his sweater, while Zenda had $10,000 cash in a plastic bag in her purse and $43,717 cash in various pouches in her purse. Although Inspector Lou did not follow, to the letter, the Customs Service’s procedures for conducting currency examinations when he examined the Ta-toyans, he did inform them that there was no law against taking money out of the United States but that, if they were carrying more than $10,000, they must declare it and file a form with the Customs…