On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified counties of California and Texas to file currency transaction reports (CTRs) for currency transactions of more than US$200 but not more than US$10,000. The regular CTR filing requirement for transactions of more than US$10,000 remains in place, but the GTO effectively reduces the threshold for such filings.

FinCEN’s authority to issue GTOs is provided by the Bank Secrecy Act (BSA), which authorizes FinCEN to order additional recordkeeping and reporting requirements upon finding reasonable grounds to conclude that such requirements are necessary to carry out the purposes of the BSA or to prevent evasions thereof. This GTO becomes effective 14 April 2025 and will expire 180 days thereafter unless it is renewed. 

This 180-day effective period is consistent with the BSA, but, as a practical matter, FinCEN tends to renew its GTOs and often expands them to cover other geographies. According to FinCEN, the new GTO is in furtherance of Treasury’s efforts to combat illicit finance by drug cartels and other illicit actors along the southwest border of the US. FinCEN can renew this GTO if it determines that to be appropriate, and/or could amend it to cover additional states, such as Arizona or New Mexico that also share a border with Mexico.

Except for the reduced dollar threshold, the “Covered Transactions” for this GTO are the same as for regular CTRs: “each deposit, withdrawal, exchange of currency or other payment or transfer, by, through or to” the covered financial institution, in this case MSBs located in the Covered Geographic Area. For all CTR purposes, “currency” means cash: the coin and paper money of the US or of any other country that is designated as legal tender.

The “Covered Geographic Area” for this GTO include 30 enumerated zip codes, including at least parts of Imperial and San Diego County of California, and Cameron, El Paso, Hidalgo, Maverick and Webb Counties of Texas. If an MSB is located in any of these zip codes and engages in Covered Transactions in any of those places, it is subject to this GTO.

Before concluding a Covered Transaction, the MSB must perform the identification requirements regarding the individual presenting the transaction and, if applicable, any individual or entity on behalf of which the transaction is to be effected, following the rules for regular CTR filings. 

The GTO does not alter the US$2,000 threshold for suspicious activity report (SAR) filings, but the GTO encourages MSBs to make voluntary SAR filings to report transactions conducted to evade the US$200 reporting threshold. 

Each MSB that is subject to this GTO is responsible for compliance by each of its officers, directors, employees, and agents. The GTO also directs each covered MSB to transmit the GTO to its agents that are located in the Covered Geographic Area.