FinCEN’s newly issued Geographic Targeting Order (GTO) for Minnesota is a clear signal of how regulators are approaching money transmission risk nationwide and why multiple, overlapping compliance tools are now part of everyday compliance reality.

Effective February 12, 2026, through August 10, 2026, the GTO requires banks and money transmitters operating in Hennepin and Ramsey Counties, Minnesota, to report certain international funds transfers of $3,000 or more directly to FinCEN. However, the implications extend far beyond these counties or even the state of Minnesota.

When viewed alongside the Southwest Border GTO, this reveals a broader regulatory strategy: FinCEN and the Treasury are leveraging geographic targeting to tackle specific criminal threats and financial crime schemes, putting pressure on MSBs to maintain dynamic, future-ready AML/CFT programs. 

Why the Minnesota GTO was Issued

The U.S. Treasury, under Secretary Scott Bessent, announced a suite of initiatives to combat “rampant government benefits fraud” in Minnesota, which Treasury officials say has resulted in billions of dollars in diverted public funds. These fraud schemes targeted programs intended for vulnerable populations and allegedly routed significant portions of those funds through international transfers.

The Minnesota GTO is designed to:

• Accelerate investigations into large-scale fraud schemes
• Improve tracking of funds laundered internationally
• Support law enforcement in recovering diverted taxpayer dollars
• Generate actionable leads from enhanced data reporting

FinCEN issued this order as a targeted response to identified financial crime flows associated with fraud schemes in Minnesota.

Who is Covered Under the Minnesota GTO?

Under FinCEN’s authority pursuant to the Bank Secrecy Act (31 CFR Chapter X), the Minnesota GTO applies to:

• Any bank or money transmitter 
• With a branch, office, subsidiary, or agent locations 
• Situated in Hennepin County or Ramsey County, Minnesota

This applies regardless of where the organization is headquartered. If the entity operates in the covered area(s), it is in scope according to FinCEN.

Covered Transactions

A covered transaction is a funds transfer that meets the following:

• $3,000 or more
• Falls under existing BSA recordkeeping rules
• The originator address is in the covered Minnesota counties
• An originator is not:
  • A publicly traded company
  • A financial institution subject to BSA AML program requirements
• Funds are sent to:
  • A recipient outside the U.S., or
  • A foreign financial institution

The GTO applies to all transmission methods, including:

• Traditional wires
• Ledger entries (including hawala-style networks)
• Convertible virtual currency (CVC) transfers
• All such qualifying transactions must be reported.

Expanded Data Requirements and Real-World Fraud Drivers

The GTO builds on existing BSA requirements and adds a long list of required data elements MSBs must report to FinCEN rather than simply retain. This includes:

• Full beneficiary identifying details
• Source of funds type
• Indicators for government contract or benefit program funds
• Ownership interest details when government dollars are involved
• Transmittal method type

While much of this information may already be collected under existing regulatory regimes, the GTO mandates it be submitted in a specific format through FinCEN’s FI Portal.

This expanded data requirement is a direct result of the fraud typologies FinCEN and Treasury identified in Minnesota, where international outflows of fraud proceeds were a key concern.

Reporting, Retention, and Penalty Exposure

Covered transactions must be filed monthly through the FinCEN FI Portal using the designated Special Measures filing type and FinCEN reference number FIN-62904-L4N7T. Records must be maintained for at least five years after the GTO’s final effective date.

Compliance failures are treated seriously:

• Civil penalties can exceed $71,000 per violation or more
• Criminal penalties include fines up to $250,000 and/or up to five years in prison

This is in accordance with the FinCEN Minnesota Fraud GTO FAQs issued January 13, 2026. 

GTOs as Predictive Signals: Minnesota + Southwest

Beyond Minnesota, FinCEN has already deployed another GTO focused on a different risk landscape: the Southwest Border GTO, which targets cash transaction reporting tied to cartel and cross-border criminal activity across parts of California, Arizona, and Texas.

Together, these orders show that geographic targeting is no longer rare or experimental; it’s part of a broader toolkit FinCEN can use to address emerging money laundering threat vectors.

For MSBs everywhere, this means:

• Regulatory priorities can shift rapidly
• Risk modeling needs to be geographic and typology-based
• Compliance frameworks must be adaptable across business lines

How MSBs Can Stay Ahead

It is imperative that MSBs move beyond reactive, check-the-box compliance and seek robust AML/CFT programs, monitoring frameworks, and remediation support that stand up to scrutiny, whether the focus is on Minnesota, the Southwest, or the next targeted region.

For MSBs across the industry, this means compliance programs must be scalable, defensible, and exam-ready at all times, not just when a GTO is announced.

Look-Back Reviews

Conducting targeted transactions through a look-back or an independent review helps:

• Identify transactions that would qualify as GTO-reportable
• Assess data gaps and documentation weaknesses
• Support remediation plans if deficiencies are discovered

Look-backs are especially important where thresholds, geography, or data requirements have changed, as they have under this GTO.

Transaction Monitoring Optimization

It is imperative that MSBs enhance their monitoring systems to:

• Flag transactions meeting GTO criteria
• Validate originator address data within covered counties
• Detect international transfers designed to evade reporting
• Strengthen escalation workflows for incomplete or unusual transactions

Effective monitoring reduces manual errors and demonstrates strong compliance governance to regulators.

AML/CFT Program Alignment

MSBs must update and operationalize their AML/CFT programs by:

• Updating policies and procedures to reflect GTO requirements
• Strengthening agent oversight and training programs
• Enhancing risk assessments to account for geographic targeting
• Supporting compliance testing and ongoing oversight

A well-documented AML/CFT framework is often the first thing examiners review when assessing GTO compliance.

Bottom Line

The Minnesota and Southwest GTOs together illustrate a new era of dynamic compliance risk, where regulators:

• Use geographic risk to uncover evolving fraud vectors
• Demand expanded data capture and reporting
• Judge MSBs on their ability to adapt systems and programs

Our team has a network of compliance and legal experts who can guide you through a GTO audit or help you prepare for future regulatory demands. If you are waiting for a Notice of Investigation (NOI) from FinCEN in order to act, it could already be too late.

MSBs should act now to:

• Seek legal/professional advice if you are in a covered business or have already received an NOI
• Validate logic across all geographies through transaction monitoring technology
• Conduct targeted look-back or independent reviews to identify historical exposure
• Strengthen agent oversight, training, and escalation protocols
• Ensure AML/CFT programs can quickly adapt to new GTOs and special measures

Our team helps MSBs build compliance programs that don’t just survive today’s GTOs but are strong enough to withstand the next one.

Tags: AML/CFT Program, Automated Transaction Monitoring, Bank Secrecy Act, BSA, Employee Training, FinCEN, Geographic Targeting Order, GTO, Independent Review, Transaction Monitoring