The Financial Crimes Enforcement Network (FinCEN) has issued updated guidance on its Geographic Targeting Order (GTO), directly affecting money services businesses (MSBs) along the southwest border.
From September 10, 2025, through March 6, 2026, MSBs in designated areas must file Currency Transaction Reports (CTRs) for cash transactions over $1,000 and up to $10,000. The updated order also expands the list of covered ZIP codes, extending compliance obligations into additional high-risk border communities.
MSBs that were already subject to the previous GTO must comply beginning September 10, 2025. Those newly included have until October 10, 2025, to come into compliance.
Key Updates to the GTO
1. New CTR Threshold
Previously, the original order required MSBs to file CTRs for transactions exceeding $200. Under the updated order, the threshold has been increased to $1,000.
This change reduces the volume of low-dollar filings while keeping a strong focus on transactions that may indicate structuring or money laundering.
2. Expanded Geographic Coverage
FinCEN has added new counties/ZIP codes across Arizona, California, and Texas:
- Arizona: Santa Cruz County and Yuma County
- California: Imperial County and San Diego County
- Texas: Cameron County, El Paso County, Hidalgo County, Maverick County, and Webb County
MSBs operating in any of these expanded counties/ZIP codes must comply with the new GTO reporting and recordkeeping requirements.
Reporting & Compliance Requirements
- File CTRs within 15 days of any covered transaction between $1,000 and $10,000.
- Include MSB0325GTO in Field 45 of the CTR when reporting.
- Verify and record customer identity in line with 31 CFR 1010.312.
- Retain reports and records for 5 years beyond the GTO’s expiration.
- Ensure reports are accessible for review by FinCEN, IRS, banks, or law enforcement.
Impact on MSBs
The updated GTO underscores FinCEN’s ongoing focus on border-region money laundering risks. By raising the CTR threshold to $1,000 and expanding ZIP code coverage, FinCEN aims to strike a balance between effective enforcement and manageable compliance for MSBs.
MSBs that fail to comply face significant civil and criminal penalties, making training, monitoring, and updating internal policies essential.
How Capital Compliance Experts Can Help
The impact of regulatory changes on daily operations can be cumbersome. We are here to help:
- Automate CTR filing and reporting workflows
- Update compliance policies to match the new $1,000 threshold
- Train staff on FinCEN’s updated requirements
- Monitor transactions for structuring risks in expanded ZIP code areas
Stay ahead of FinCEN’s evolving requirements. Contact us today to discover how we can help your business stay compliant while minimizing the reporting burden.
