Gospel for Asia sponsors frequent “vision trips” to India. These trips help inspire donors and prospective ministry workers to give time and money to the work of GFA. In Texas, GFA runs a School of Discipleship and the students at the school often go as a group to India as a part of their work. According to some former GFA travelers, they pack more than cameras and a toothbrush.
For over two years, some GFA travelers to India have been packing envelopes of cash designed to be taken into India and given unopened to GFA headquarters in Kerala, India. According to my sources, GFA staff in Texas have on multiple occasions given GFA travelers sealed envelopes filled with cash and said that the envelope contained $4500. The travelers — who were traveling together in groups of various sizes — were told the figure of $4500 was designed to avoid the need to declare the cash in India. Amounts of $5000 or more must be declared upon arrival. According to federal law, any amount of cash may be taken out of the country, but amounts of $10,000 or more must be declared when leaving or entering the U.S. According to my sources, the GFA groups were carrying far more than $10,000 per trip.
Over the last several days, I have spoken to five GFA travelers* who carried money to India in this manner and have examined GFA source information which described the practice. The sources said that most if not all members of their groups carried the envelopes filled with $4500. For instance, a group of ten people carried $45,000. I asked GFA COO David Carroll for comment but he has not replied.
Pushing the Envelope
One individual told me that a GFA leader told a group of travelers that taxes were high in India and by taking undeclared cash, the ministry would benefit. According to all sources, each individual in the GFA groups received a sealed envelope from GFA leaders in Texas. I was told that one group had ten people carrying cash ($45,000 at one time) and another source said there were 30 travelers in a group (a maximum of $135,000). The travelers were told that each package contained $4500 and that each member of the group would turn in the envelope to a GFA leader in Kerala, India. The money did not belong to the travelers and was not to be used for expenses. The envelopes were to remain sealed and turned over to a GFA leader at headquarters or a Synod office for the Believers Church. Some specifically named Siny Punnose, who works in finance for GFA in India. Some groups consisted of students, some of ministry partners, and at times, pastors have been asked to carry funds.
All sources felt odd about taking the money. One person said fear of losing it or having it stolen was a constant preoccupation. They worried they were doing something that didn’t sound right. Even though the leaders assured them that the practice was fine, it still didn’t seem right.
And, in fact, the travelers may have been right to worry.
Currency Structuring
One may leave or enter the United States with any amount of cash. However, a person who has $10,000 or more must declare it on a form designed by Customs and Border Protection when leaving or entering the U.S. As a recent CBP press release says, one may not split it up and have others carry it for you. In this case, GFA asked the travelers to carry much more than the $10,000 limit in total.
If travelers have someone else carry the currency or monetary instrument for them, they must file a currency report for the entire amount with CBP. Failure to report may result in seizure of the currency and/or arrest.
Another CBP press release tells of an Italian man who attempted to come into the country with more than $10k along with “co-travelers.”
During a secondary inspection, the man, who arrived from Italy, reported possessing $11,700. It was later discovered that the man had given money to two co-travelers in order to evade currency reporting requirements, an illegal practice known as currency structuring. In total the cash added up to $24,644. CBP officers seized the money, issued the man a $1,000 penalty, and then returned the remaining cash back to the man.
The reporting requirements apply to travelers leaving and entering the country.
International travelers who arrive or depart the United States in possession of more than $10,000 or equivalent foreign currency are required to report all currency to CBP officers and complete a Treasury Department Financial Crimes Enforcement Network (FinCEN) form. (emphasis added)
Federal law appears to forbid such undeclared money moves without declaration. None of my sources report any forms filed. Note that the relevant federal law forbids aiding, commanding, or requesting such moves in the aggregate:
§ 103.23 Reports of transportation of currency or monetary instruments.
(a) Each person who physically transports, mails, or ships, or causes to be physically transported, mailed, or shipped, or attempts to physically transport, mail or ship, or attempts to cause to be physically transported, mailed or shipped, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time from the United States to any place outside the United States, or into the United States from any place outside the United States, shall make a report thereof. A person is deemed to have caused such transportation, mailing or shipping when he aids, abets, counsels, commands, procures, or requests it to be done by a financial institution or any other person. (emphasis added)(b) Each person who receives in the U.S. currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time which have been transported, mailed, or shipped to such person from any place outside the United States with respect to which a report has not been filed under paragraph (a) of this section, whether or not required to be filed thereunder, shall make a report thereof, stating the amount, the date of receipt, the form of monetary instruments, and the person from whom received.
I am not an attorney and realize that there may be some unknown facts which make this all fine. However, it seems strange to me. GFA can wire money to India and does so frequently. There are many other ways to get money to the field which can be verified transparently. If these travelers are accurate in their reports, GFA is causing hundreds of thousands of dollars in cash to be transported without declaration. This practice seems risky and fraught with many negatives and potentials for abuse.
I want to repeat that on Tuesday I asked GFA’s David Carroll for comment and explanation.
*All sources spoke on condition of anonymity for fear of retaliation from GFA. None of the people I spoke with are affiliated with the GFA Diaspora.