On September 2, 2026, the Financial Crimes Enforcement Network (FinCEN) renewed its Southwest Border Geographic Targeting Order (GTO), but if you have been following the GTO since its original issuance in March 2025, you will immediately notice something different: California and Arizona are no longer included in the current GTO map.
The reissuance continues enhanced reporting requirements for certain money services businesses (MSBs), with the GTO remaining focused on identifying and disrupting illicit cash activity associated with Mexico-based cartels, drug trafficking, and other criminal activity along the Southwest Border.
What Changed?
Several key requirements remain unchanged. Covered MSBs must continue to file Currency Transaction Reports (CTRs) for cash transactions of $1,000 or more, but not more than $10,000, and the 30-day CTR filing deadline remains in place.
Aside from the renewed GTO being effective for another 180 days, from September 3, 2026, through March 1, 2027, MSBs need to understand some important changes.
The Geographic Coverage
The most significant change is the GTO’s geographic coverage. Unlike the March 2026 GTO, which included portions of Arizona, California, New Mexico, and Texas, the renewed order now covers specific ZIP codes in:
- New Mexico: Bernalillo, Doña Ana, and San Juan Counties
- Texas: Cameron, El Paso, Hidalgo, Maverick, and Webb Counties
Arizona and California are no longer included in the current GTO’s Covered Geographic Area.
This means an MSB should not assume that being located in a county previously covered by the GTO automatically means it remains covered today. MSBs should review the current order and its specific ZIP-code requirements to determine whether the GTO applies to their locations.
The CTR Identifier
The CTR identifier has also been updated. Under the renewed GTO, covered MSBs must use MSB0926GTO in Field 45 of the CTR. MSBs should review their CTR filing procedures and systems to ensure they use the new identifier.
While the reporting threshold and filing deadline remain the same, the map and CTR identifier have changed, and the order must be evaluated based on current geographic coverage, not previous GTO requirements.
Why Is California No Longer on the Map?
California’s absence is closely connected to litigation challenging FinCEN’s original Southwest Border GTO.
In March 2025, FinCEN issued the original GTO requiring MSBs in designated ZIP codes in California and Texas to file CTRs for cash transactions above $200. The order was subsequently challenged in court.
In July 2026, the U.S. Court of Appeals for the Ninth Circuit affirmed a preliminary injunction preventing the government from enforcing the March 2025 GTO against covered MSBs in the Southern District of California, which includes San Diego and Imperial Counties.
At the preliminary-injunction stage, the court concluded that the plaintiffs were likely to succeed on claims that the GTO functioned as a rule requiring notice-and-comment procedures under the Administrative Procedure Act.
That litigation matters because FinCEN’s subsequent GTOs have specifically recognized the injunction.
The March 2026 GTO, for example, included California ZIP codes in Imperial and San Diego Counties but stated that MSBs protected by the injunction were exempt from the definition of a covered business while the injunction remained in effect.
Now that California is no longer included in the renewed map, it does not mean that it has been permanently removed from FinCEN’s enforcement priorities.
Rather, the current GTO reflects the legal landscape surrounding the original order. The Ninth Circuit’s decision remains significant, and the litigation itself is ongoing. The court’s ruling was a preliminary injunction, not a final determination that FinCEN can never impose enhanced reporting requirements in the region.
What About Arizona?
Arizona’s removal is different.
Arizona was included in the March 2026 GTO, which covered Maricopa, Pima, Santa Cruz, and Yuma Counties.
The September 2026 renewal, however, does not include any Arizona counties.
Unlike California, the current FinCEN materials do not identify an Arizona injunction as the reason for removing the state from the renewed GTO. Instead, FinCEN has revised the geographic scope of the order to focus on specific ZIP codes in Texas and New Mexico.
Arizona’s absence from the new map should be viewed as a change in the geographic scope of the renewed GTO, not as a litigation-based exemption.
In other words, Arizona MSBs that are no longer within the current Covered Geographic Area are not subject to this particular GTO simply because Arizona has been removed from the order.
What Does the Litigation Mean for Texas?
The litigation also continues to affect how the GTO applies to certain Texas MSBs.
MSBs in both California and Texas challenged the original March 2025 GTO. Subsequent GTOs have included language excluding MSBs against whom the government is enjoined from applying the March 2025 GTO, for as long as the applicable injunction remains in effect.
An MSB must also determine whether it falls within an applicable litigation-related exemption.
This is one reason the renewed GTO should not be treated as simply a geographic checklist. Compliance teams need to consider:
- Where the MSB and its agents are located
- Whether the location falls within a currently covered ZIP code
- Whether an applicable court injunction affects the business
- Whether the business was previously covered under an earlier GTO
- Whether its CTR procedures reflect the current $1,000 threshold and 30-day filing requirement
The Southwest GTO Has Evolved
The Southwest Border GTO has changed considerably since its original issuance.
March 2025:
FinCEN initially targeted 30 ZIP codes in California and Texas and established a $200 reporting threshold.
September 2025:
FinCEN raised the reporting threshold to $1,000, extended the CTR filing period to 30 days, and expanded the geographic footprint to include Arizona.
March 2026:
FinCEN expanded the GTO again, adding New Mexico and additional areas of Arizona while continuing coverage in Texas and specified California ZIP codes.
September 2026:
FinCEN has now revised the map again, limiting the current GTO to specific ZIP codes in New Mexico and Texas. California and Arizona are no longer included.
The Takeaway
The latest Southwest Border GTO is a reminder that regulatory requirements can move quickly.
California’s removal reflects a significant legal development. Arizona’s removal reflects a revised geographic scope. Texas remains covered, while New Mexico continues under the order with specific ZIP-code coverage.
For MSBs, the takeaway is simple: Don’t rely on yesterday’s GTO map. Review today’s requirements.
If your business has been affected by the Southwest Border GTO, or you want to ensure your AML/CFT program is prepared and transaction monitoring alerts are set, we can help you identify what needs to change and put the right controls in place.
Tags: AML, AML/CFT Program, Anti Money Laundering, CFT, Countering the Financing of Terrorism, CTR, Currency Transaction Report, Financial Crimes Enforcement Network, FinCEN, Geographic Targeting Order, GTO, Money Services Business, MSB, Risk Assessment
