The Financial Crimes Enforcement Network (FinCEN) has reissued a modified Geographic Targeting Order (GTO) aimed at illicit cartel and other criminal activity along the US southwest border, requiring certain money services businesses (MSBs) to file Currency Transaction Reports (CTRs) for cash transactions between USD 1,000 and USD 10,000 in specified counties and ZIP codes. The new GTO replaces a March measure that applied a USD 200 reporting threshold in 30 ZIP codes in California and Texas and was set to run through September 9, 2025. Under the modified order, the terms apply from September 10, 2025 through March 6, 2026, and the covered geography includes Santa Cruz County and Yuma County (Arizona); Imperial County ZIP codes 92231, 92249, 92281, 92283 and San Diego County ZIP codes 91910, 92101, 92113, 92117, 92126, 92154, 92173 (California); and Cameron, El Paso, Hidalgo, Maverick, and Webb counties (Texas). For the full GTO period, FinCEN also extends the CTR filing deadline for covered MSBs from the standard 15 days to 30 days. MSBs newly brought into scope are given a 30-day compliance period and do not need to begin filing under the GTO until October 10, 2025.
Financial Crimes Enforcement Network 2025-09-08
Financial Crimes Enforcement Network reissues modified southwest border Geographic Targeting Order requiring MSBs to report USD 1,000 to USD 10,000 cash transactions
FinCEN has reissued a modified Geographic Targeting Order (GTO) targeting illicit activities along the US southwest border, requiring certain money services businesses (MSBs) to file Currency Transaction Reports (CTRs) for cash transactions between USD 1,000 and USD 10,000 in specified areas. The new GTO, effective from September 10, 2025, to March 6, 2026, replaces a previous order with a USD 200 threshold and extends the CTR filing deadline from 15 to 30 days. Newly included MSBs have until October 10, 2025, to comply.