The Financial Crimes Enforcement Network issued a new Geographic Targeting Order (GTO) on March 7, 2026, that renews and expands U.S. southwest border prior reporting requirements for certain cash transactions conducted through money services businesses (MSBs).

This latest order builds on the series of GTO updates we’ve covered previously and reflects the government’s ongoing effort to identify and disrupt illicit finance tied to drug cartels, human smuggling, and other criminal organizations operating along the border.

If you’ve been following our compliance alerts, this new development represents the next phase in FinCEN’s evolving GTO enforcement strategy.

A Quick Timeline of the Southwest Border GTO

FinCEN’s approach to monitoring MSBs in high-risk border regions has evolved rapidly over the past year. 

On March 19, 2026, FinCEN released FAQs related to the Southwest GTO.

The Original $200 GTO Threshold

In early 2025, FinCEN issued the initial southwest border GTO requiring certain MSBs to file Currency Transaction Reports (CTRs) for cash transactions of $200 up to $10,000.

This order targeted specific ZIP codes in California and Texas and required MSBs to verify customer identity and maintain records for those transactions.

FinCEN Raises the CTR Threshold to $1,000

In September 2025, FinCEN modified the GTO in response to industry concerns and legal challenges, raising the reporting threshold to $1,000 and expanding geographic coverage.

This change was intended to reduce compliance burden on legitimate businesses while still providing law enforcement with actionable financial intelligence.

What Has Changed in the 2026 GTO

FinCEN has now issued a new version of the Southwest Border GTO, which replaces the previous order that expired in early March 2026.

Key Updates

New Order Period

• The current GTO is effective March 7, 2026, through September 2, 2026.
• Newly covered MSBs, not covered by the previous order, have until April 6, 2026, to comply.

Reporting Threshold Remains $1,000

• Covered MSBs must continue to report cash transactions of $1,000 up to $10,000.
• CTRs must be filed within 30 days of the transaction, instead of the standard 15-day requirement.

CTR Identifier Code

• To file a CTR, use the BSA E-Filing portal.
• In field 45, reference MSB0326GTO

Expanded Geographic Coverage/New Covered Business

• The 2026 order now applies to multiple counties across Arizona, California, New Mexico, and Texas. This includes:
  • Arizona
    • Maricopa County
    • Pima County
    • Santa Cruz County
    • Yuma County
  • California
    • Imperial County
      • 92231
      • 92249
      • 92281
      • 92283
    • San Diego County
      • 91910
      • 92101
      • 92113
      • 92117
      • 92126
      • 92154
      • 92173
  • New Mexico
    • Bernalillo County
    • Dona Ana County
    • San Juan County
  • Texas
    • Cameron County
    • El Paso County
    • Hidalgo County
    • Maverick County
    • Webb County 

Reporting Exemptions

There are currently MSBs that are exempt from the GTO reporting requirements due to ongoing litigation. They are temporarily not considered a “Covered Business” until the injunctions are lifted. 

• California
  • All MSBs in the zipcodes listed above for CA 
• Texas
  • Specific MSBs involved in relevant litigation

Why FinCEN is Targeting MSBs

The southwest border continues to be a major focus for federal financial crime enforcement. FinCEN has stated that these GTOs are part of a broader effort to detect and prevent money laundering tied to drug trafficking, human smuggling, and other organized criminal activity.

Due to MSBs’ large volumes of cash transactions, regulators consider them a critical point for detecting suspicious financial activity.

What This Means for MSBs

If your business operates in a covered area, you should ensure that your compliance program includes:

• Updated CTR policies and procedures
• Proper customer identity verification
• Monitoring for structuring or evasion of the $1,000 threshold
• Accurate and timely CTR filing through the BSA E-Filing system
• Record retention for five years

Failure to comply with a GTO can expose MSBs to significant regulatory penalties and enforcement actions.

Need help preparing for the latest GTO requirements?

Contact Capital Compliance Experts today to ensure your policies, systems, and reporting processes are fully compliant.

Tags: BSA, CTR, Currency Transaction Report, FinCEN, Geographic Targeting Order, GTO