FinCEN Reissues Geographic Targeting Order for Money Services Businesses Along the Southwest Border
The full text of the reissued GTO is available here. FinCEN’s press release can be found here. We have covered prior iterations of this GTO on our blog and will continue to monitor developments in this area.
Here is what you need to know.
Why Another GTO?FinCEN has been issuing and renewing these southwest border GTOs since early 2025.Under the Bank Secrecy Act (BSA), FinCEN can impose additional recordkeeping and reporting obligations on financial institutions and other businesses in a specific geographic area when it determines those requirements are necessary to carry out the BSA’s purposes or prevent evasion. Each GTO lasts up to 180 days, which is why we see periodic renewals.
The broader context here is the Administration’s ongoing campaign against Mexico-based drug cartels. Secretary of the Treasury Scott Bessent framed the reissued GTO as a tool to “ensure law enforcement has the actionable data they need to follow the money.” That language tracks with the Administration’s broader strategy: Executive Order 14157 (January 20, 2025) established a process for designating cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists, and in February 2025, Treasury and State designated eight organizations, including six major Mexican cartels, under those authorities.
FinCEN has observed that MSBs along the southwest border face heightened money laundering risks, given their proximity to regions where cartels are actively moving illicit cash connected to drug, human, and weapons trafficking. The GTO’s reporting requirements, shaped by law enforcement input, are designed to generate investigative leads and support prosecutions targeting cartel-linked financial activity.
What Does the GTO Actually Require?The bottom line: if you are an MSB in one of the covered ZIP codes, you need to file CTRs with FinCEN for cash transactions between $1,000 and $10,000. That threshold is below the standard $10,000 CTR requirement.
The covered geographic areas include specific ZIP codes in:
A “Covered Transaction” is any deposit, withdrawal, currency exchange, or other payment or transfer in currency of $1,000 or more but not more than $10,000. One important limitation: the GTO applies only to transactions conducted in a business’s MSB capacity, i.e., foreign currency exchange, check cashing, money orders, prepaid access, and money transmission. It does not reach other services an MSB business may offer, like retail sales. The reissued GTO is effective September 3, 2026, through March 1, 2027 and reports must be e-filed through the BSA E-Filing System.
Existing BSA Obligations Remain in EffectThe GTO is additive and does not replace or modify any of the existing BSA requirements that already apply to Covered Businesses. Standard CTRs for transactions over $10,000 and Suspicious Activity Reports (SARs) still need to be filed as usual. FinCEN is also encouraging voluntary SAR filings for transactions that look like they are structured to duck the $1,000 GTO threshold.
Record Retention and PenaltiesWhat Should You Be Doing?If you are an MSB in one of the covered areas, key action items include:
FinCEN has published a detailed set of FAQs alongside the order that address common questions about covered transactions, aggregation, filing procedures, and more. We recommend reviewing both the GTO itself and the FAQs carefully.
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