FinCEN Issues New GTO for Minnesota Financial Institutions

FinCEN issued a Geographic Targeting Order ("GTO") requiring banks and money transmitters in specific Minnesota counties to report certain funds transfers of $3,000 or more.

The agency stated the Order is designed to combat international money laundering involving the proceeds of government benefits fraud. Reporting is required for transactions in specific counties in Minnesota, where the originator provides a local address and the funds are destined for a beneficiary or financial institution located outside of the United States.

Covered businesses must file reports through the FinCEN Financial Industry Portal by the end of the month following the transaction. Required data includes the name, address, and contact information of the beneficiary, as well as specific declarations regarding:

• Whether the source of funds includes payments from federal, state, or local government benefit programs or contracts;
• Whether the transaction involves convertible virtual currency; and
• For money transmitters, whether the transaction involves ledger entries with an international network of money brokers called "hawaladars" settled via cash couriers.

The GTO takes effect on February 12, 2026, and expires on August 10, 2026.