On September 2, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) reissued its Geographic Targeting Order (GTO) aimed at money services businesses (MSBs) along the U.S. southwest border. The GTO requires certain MSBs in designated border communities to file Currency Transaction Reports (CTRs) on cash transactions that would otherwise fall below the standard reporting threshold.
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.
Link to Why Another GTO? 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.
Link to What Does the GTO Actually Require? 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:
- Texas: Cameron, El Paso, Hidalgo, Maverick, and Webb Counties
- New Mexico: Bernalillo, Dona Ana, and San Juan Counties
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.
Link to Existing BSA Obligations Remain in Effect Existing BSA Obligations Remain in Effect
The 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.
Link to Record Retention and Penalties Record Retention and Penalties
Penalties for noncompliance are significant. Willful violations may result in civil penalties of the greater of $71,545 or the transaction amount (up to $286,184), assessed separately for each violation. This liability extends to individual partners, directors, officers, and employees who participate in the violation. Criminal penalties may include fines of up to $250,000 and imprisonment for up to five years.
Link to What Should You Be Doing? What Should You Be Doing?
If you are an MSB in one of the covered areas, key action items include:
- Confirming whether your business falls within the covered ZIP codes and meets the definition of a Covered Business
- Ensuring you can identify and report Covered Transactions (cash transactions of $1,000–$10,000) within 30 days
- Registering for the BSA E-Filing System if you have not already done so
- Updating record retention protocols to meet the five-year requirement
- If newly covered, marking October 3, 2026, on the calendar as your compliance deadline
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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