The Financial Crimes Enforcement Network (FinCEN) has issued a Geographic Targeting Order (GTO) requiring money services businesses (MSBs) along the southwest border of the United States to file Currency Transaction Reports (CTRs) for cash transactions exceeding $200 but not more than $10,000.
Effective April 14, 2025, through September 9, 2025, this order aims to enhance Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) efforts by identifying and deterring illicit financial activities, particularly those linked to drug cartels and other criminal organizations.
Key Requirements of the GTO
Covered Businesses and Transactions
The GTO applies to MSBs located in designated counties, specifically applying to 30 designated ZIP codes in California and Texas. Covered transactions include any deposit, withdrawal, exchange, or transfer involving currency amounts between $200 and $10,000.
Note: Cash transactions received or sent (cash-in or cash-out) to the covered zip codes below should file a CTR under the GTO requirements.
Affected Geographic Areas
The GTO covers seven counties along the southwest border, specifically targeting areas with heightened money laundering risks:
- California
- Imperial County: 92231, 92249, 92281, 92283
- San Diego County: 91910, 92101, 92113, 92117, 92126, 92154, 92173
- Texas
- Cameron County: 78520, 78521
- El Paso County: 79901, 79902, 79903, 79905, 79907, 79935
- Hidalgo County: 78503, 78557, 78572, 78577, 78596
- Maverick County: 78852
- Webb County: 78040, 78041, 78043, 78045, 78046
Reporting & Recordkeeping Obligations
Currency Transaction Reports (CTRs)
MSBs involved in covered transactions must file CTRs with FinCEN within 15 days of the transaction. While financial institutions normally report only transactions over $10,000, this GTO requires MSBs to report much smaller transactions, starting at $200.
When filing, you must reference MSB0325GTO in field 45 (Alternative Name, e.g. trade name, DBA)
Note: MSBs may receive a system warning indicating the transaction is below $10,000, but they must still submit the report.
Customer Identification
Before completing a covered transaction, MSBs must verify and record the customer’s identity in accordance with 31 CFR 1010.312. This includes recording specific identifying information (e.g., driver’s license number, account number). General notations such as “known customer” are not acceptable.
E-Filing and Record Retention
Reports must be e-filed through FinCEN’s BSA E-Filing System. MSBs are required to:
- Retain all reports and related records for five years beyond the GTO’s expiration date.
- Ensure records are readily accessible for an Independent Review, bank, FinCEN, IRS, or law enforcement.
Note: The BSA e-filing system does not let you access your filed reports, so it is important that you keep a copy on your local server.
Penalties for Noncompliance
MSBs and their officers, directors, employees, and agents may face civil or criminal penalties for failing to comply with the GTO. These penalties may include substantial fines or other enforcement actions.
Purpose & Impact
The GTO is part of FinCEN’s broader effort to combat illicit financial activity in border regions prone to exploitation by criminal organizations. By lowering the reporting threshold to $200, the Treasury aims to detect and deter structuring activities designed to evade AML/CFT regulations.
While the GTO imposes additional reporting requirements, it does not alter existing obligations under the Bank Secrecy Act (BSA). MSBs must continue filing CTRs for transactions over $10,000 and Suspicious Activity Reports (SARs) for suspicious transactions, including those designed to evade the GTO’s lower threshold and/or for possible suspicious transactions in nearby zip codes not included in GTO.
Compliance Requirements for MSBs
To ensure compliance with the GTO, MSBs need to:
- Train employees on the new reporting thresholds and verification requirements.
- Implement enhanced monitoring for structuring attempts.
- Update internal policies to align with the GTO’s requirements.
- Maintain accurate and accessible records to avoid potential penalties.
- You may notify customers that additional personal information will be required for cash transactions $200 or over.
Conclusion
The Geographic Targeting Order demonstrates FinCEN’s intensified focus on border-region money laundering risks. MSBs operating in the covered counties must prepare to comply with the expanded reporting and recordkeeping requirements. By doing so, they contribute to the fight against illicit finance while protecting their business from potential enforcement actions.
At Capital Compliance Experts, we specialize in helping MSBs navigate complex regulatory requirements like those outlined in this GTO. From CTR filing support and policy updates to employee training and ongoing compliance monitoring, our team ensures your business remains fully compliant with FinCEN mandates. Contact us to learn how we can support your CTR and BSA compliance needs.
