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FinCEN Modifies Southwest Border Geographic Targeting Order

"The reports generated by this Geographic Targeting Order will continue to help law enforcement investigate powerful illicit networks operating along the southwest border and beyond."
Andrea Gacki, FinCEN Director
"The reports generated by this Geographic Targeting Order will continue to help law enforcement investigate powerful illicit networks operating along the southwest border and beyond."
Andrea Gacki, FinCEN Director

FinCEN issued a modified Geographic Targeting Order ("GTO") "requiring [money] services businesses along the southwest border … to report and retain records of currency transactions [exceeding] $1,000 but not [exceeding] $10,000, and to verify the identity of [individuals conducting] such transactions."

The modified Order updates an earlier GTO that required money services businesses in certain ZIP codes in California and Texas to report cash transactions over $200 up to $10,000 within 15 days. (See related coverage.) The revised order narrows the scope by raising the reporting threshold to transactions over $1,000 but not exceeding $10,000, while also extending the filing deadline to 30 days. It further broadens the geographic reach to include designated counties and ZIP codes in Arizona as well as California and Texas.

The Order remains in effect for 179 days, beginning September 10, 2025, with a compliance date of October 10, 2025, for money services businesses newly subject to the reporting requirements.

Primary Sources

  1. FinCEN: Press Release: FinCEN Issues Modified Southwest Border Geographic Targeting Order
  2. FinCEN: Order: Geographic Targeting Order Imposing Recordkeeping and Reporting Requirements on Certain Money Services Businesses Along the Southwest Border

Related Articles

  • FinCEN Requires Reporting of Small Dollar Transactions Near Mexico

    FinCEN issued a Geographic Targeting Order "requiring [money] services businesses along the southwest border ... to report and retain records of currency transactions [exceeding] $200 but not [exceeding] $10,000, and to verify the identity of [individuals conducting] such transactions."

Tags

Regulated Activities
AML Compliance
Sub-Activity
Geographic Targeting Orders
Regulated Entities
Money Service Business / Transmitter
Body of Law
AML Regulation
Jurisdiction
US - Federal
Organization
Treasury / FinCEN / OFAC / CFIUS
Sub-Author
Treasury