On September 8, the Treasury through FinCEN issued additional reporting requirements on financial institutions through its Geographic Targeting Order (GTO). This GTO will require certain money services businesses along the southwest border to file Currency Transaction Reports with FinCEN for cash transactions between $1,000 and $10,000 occurring in specific counties and ZIP codes, retain records of these currency transactions, and verify the identity of the individuals conducting the transactions. As previously covered by InfoBytes, this order followed a previous directive from March 2025 that had mandated reporting transactions exceeding $200, which is lower than the new threshold of $1,000.
The Treasury stated this action would combat illicit finance by drug cartels and other criminal behavior near the southwest boarder. Covered businesses may face civil or criminal penalties for violating the order. The order also requires businesses to file reports within 30 days of qualifying transactions, retain records for five years, and ensure compliance among staff and agents. The new requirements apply to businesses in specified counties in Arizona, Texas and California. The terms of this GTO are effective September 10, 2025, through March 6, 2026, and the GTO provides a 30-day compliance period for money service businesses that were not required to report under the March GTO, and will be exempt from filing reports until October 10, 2025.
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