What happened?

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at combating Mexico-based cartels and other criminals along the southwest border of the United States.

Overview:

This GTO is part of a broader effort by the U.S. government to combat illicit financial activities and enhance security along the southwest border. Compliance is crucial to avoid civil or criminal penalties.

FinCEN GTO Summary:

• Duration: 179 days (until September 9, 2025)

• Scope: Money services businesses (MSBs) in 30 ZIP codes across California and Texas

• Requirements:
  
  • Currency Transaction Reports (CTRs): MSBs must file CTRs for cash transactions between $200 and $10,000.
  • Identification: MSBs must verify and record the identities of individuals conducting transactions, including names, addresses, and tax identification numbers.
  • Suspicious Activity Reports (SARs): FinCEN encourages MSBs to file SARs for transactions designed to evade the $200 reporting threshold.

• Affected ZIP Codes:
  
  • 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

• Compliance:
  
  • Verification: MSBs must use valid documents like driver’s licenses or passports for identity verification.
  • Recordkeeping: Detailed information on transactions and verification methods must be maintained.

• Exclusions: Not Applicable to Banks and entities regulated by the SEC or CFTC.

Source References

• FinCEN Issues Southwest Border Geographic Targeting Order
• Federal Register – Issuance of a Geographic Targeting Order Imposing Additional Recordkeeping and Reporting Requirements on Certain Money Services Businesses Along the Southwest Border
• Department of Treasury Press Release

Resources

• FinCEN FAQs regarding the GTO

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