FinCEN Geographic Targeting Order: Southwest Border Money Services Businesses
Summary
FinCEN has issued a Geographic Targeting Order (GTO) requiring certain money services businesses along the U.S. southwest border to report and retain records of currency transactions between $1,000 and $10,000. This order aims to combat illicit finance by drug cartels and other illicit actors.
What changed
FinCEN has issued a new Geographic Targeting Order (GTO) that mandates specific money services businesses (MSBs) located in a designated southwest border area to report and retain records for currency transactions ranging from $1,000 to $10,000. This order, effective March 7, 2026, requires these MSBs to verify the identity of individuals conducting such transactions. While existing BSA obligations like filing Currency Transaction Reports (CTRs) for transactions over $10,000 and Suspicious Activity Reports (SARs) remain, FinCEN encourages voluntary SAR filings for transactions designed to evade the new $1,000 reporting threshold.
Covered MSBs must comply with these new reporting and recordkeeping requirements by April 6, 2026. This GTO is part of a broader strategy to combat illicit finance and drug cartel activities along the U.S. southwest border. Failure to comply with the GTO could result in penalties associated with BSA violations. Regulated entities should review the specific geographic coverage and transaction definitions within the order to ensure full compliance by the specified deadline.
What to do next
- Identify if operating as a 'Covered Business' under the GTO based on location and business type.
- Implement procedures to report and retain records for currency transactions between $1,000 and $10,000.
- Ensure identity verification processes are in place for all covered transactions.
Source document (simplified)
Content
ACTION:
Order.
SUMMARY:
FinCEN is issuing this Geographic Targeting Order, requiring certain money services businesses along the southwest border
of the United States to report and retain records of transactions in currency of $1,000 or more, but not more than $10,000,
and to verify the identity of persons presenting such transactions.
DATES:
Effective date: This action takes effect March 7, 2026.
Compliance date: The compliance date for persons that were not Covered Businesses under the Geographic Targeting Order published by FinCEN
on September 10, 2025 (90 FR 43557) is April 6, 2026.
FOR FURTHER INFORMATION CONTACT:
FinCEN's Regulatory Support Section by submitting an inquiry at www.fincen.gov/contact.
SUPPLEMENTARY INFORMATION:
I. Background
If the Secretary of the Treasury (Secretary) finds, upon his own initiative or at the request of an appropriate Federal or
State law enforcement official, that reasonable grounds exist for concluding that additional recordkeeping and reporting requirements
are necessary to carry out the purposes of the Bank Secrecy Act (BSA) (1) or to prevent evasions thereof, the Secretary may issue a Geographic Targeting Order (GTO) requiring any domestic financial
institution or group of domestic financial institutions, or any domestic nonfinancial trade or business or group of domestic
nonfinancial trades or businesses, in a geographic area to obtain such information as the Secretary may describe in such GTO
concerning any transaction in which such financial institution or nonfinancial trade or business is involved in for the payment,
receipt, or transfer of funds (as the Secretary may describe in such GTO), and concerning any other person participating in
such transaction. (2) For any such transaction, the Secretary may require the financial institution or nonfinancial trade or business to maintain
a record and/or file a report in the manner and to the extent specified. (3) The maximum effective period for a GTO is 180 days unless renewed. (4) The authority of the Secretary to issue a GTO has been delegated to the Director of FinCEN (Director). (5)
The Director finds that reasonable grounds exist for concluding that the additional recordkeeping and reporting requirements
set forth in the GTO contained in this document (the “Order”) are necessary to carry out the purposes of the BSA or to prevent
evasions thereof. This action is being taken in furtherance of Treasury's efforts to combat illicit finance by drug cartels
and other illicit actors along the southwest border of United States. The Order does not alter any existing BSA obligation
of a Covered Business (as defined in the Order), except as otherwise noted in the Order itself. Thus, for example, a Covered
Business must continue to file Currency Transaction Reports (CTRs) for transactions in currency above $10,000 and Suspicious
Activity Reports (SARs) where appropriate and in accordance with the BSA and applicable regulations. Although the dollar thresholds
for filing SARs in the SAR regulation applicable to Covered Businesses remains the same (as low as $2,000), (6) FinCEN encourages the voluntary filing of SARs where appropriate to report transactions conducted to evade the $1,000 reporting
threshold imposed by the Order.
II. Geographic Targeting Order
A. Businesses and Transactions Covered by This Order
For purposes of this Order, the “Covered Business” means a money services business, as defined in 31 CFR 1010.100(ff),
located in the Covered Geographic Area, except, for the period during which an applicable injunction remains in force, any
money services business to which the government is enjoined by court order from applying the Geographic Targeting Order published
by FinCEN on March 14, 2025 (90 FR 12106).For purposes of this Order, a “Covered Transaction” means each deposit, withdrawal, exchange of currency or other payment
or transfer, by, through, or to the Covered Business which involves a transaction in currency, of $1,000 or more, but not
more than $10,000.For purposes of this Order, a “Covered Geographic Area” means:
a. The following counties in Arizona:
i. Maricopa County, Arizona;
ii. Pima County, Arizona;
iii. Santa Cruz County, Arizona; and
iv. Yuma County, Arizona;
b. The following counties in Texas:
i. Cameron County, Texas;
ii. El Paso County, Texas;
iii. Hidalgo County, Texas;
iv. Maverick County, Texas; and
v. Webb County, Texas; (7)
b. The following counties in New Mexico:
i. Bernalillo County, New Mexico;
ii. Dona Ana County, New Mexico;
iii. San Juan County, New Mexico; and
c. The following ZIP Codes in California:
i. 92231, 92249, 92281, and 92283 (Imperial County, California); and
ii. 91910, 92101, 92113, 92117, 92126, 92154, and 92173 (San Diego County, California). (8)
- All terms used but not otherwise defined herein shall have the same meaning set forth in part 1010 of chapter X of subtitle B of title 31 of the Code of Federal Regulations.
B. Reports Required To Be Filed by the Covered Business
- Except as otherwise set forth in this Order, if the Covered Business is involved in a Covered Transaction, then the Covered Business shall report the Covered Transaction to FinCEN on a Currency Transaction Report within 30 days following the day on which the Covered Transaction occurred. In the case of the U.S. Postal Service, the obligation contained in the preceding sentence shall not apply to payments or transfers made solely in connection with the purchase of postage or philatelic products.
Note:
When submitting the report, the Covered Business may receive a warning that the transaction is below $10,000. The Covered
Business shall ignore the warning and continue with the submission.
Each report filed pursuant to this Order must be: (a) completed in accordance with the terms of this Order and the Currency
Transaction Report instructions (when those terms and those instructions conflict, the terms of this Order prevail); and (b)
e-filed though the BSA E-Filing System. (9)Before concluding a Covered Transaction, the Covered Business must comply with the identification requirements set forth
at 31 CFR 1010.312, including the requirement that the specific identifying information (e.g., the account number of the credit card, the driver's license number) used in verifying the identity of the customer shall be
recorded on the Currency Transaction Report, and the mere notation of “known customer” or “bank signature card on file” on
the report is prohibited. For purposes of this requirement, the Covered Business need not identify employees of armored car
services.The Covered Business is not required to file a report otherwise required under this Order on a Covered Transaction between
the Covered Business and a commercial bank.Part IV of the Currency Transaction Report shall contain the following information in Field 45: “MSB0326GTO”.
C. Order Period
The terms of this Order are effective beginning March 7, 2026 and ending on September 2, 2026. The compliance date for persons
that were not Covered Businesses under the Geographic Targeting Order published by FinCEN on September 10, 2025 (90 FR 43557)
is April 6, 2026.
D. Retention of Records
The Covered Business must: (a) retain all reports filed to comply with this Order and any other records relating to compliance
with this Order for a period of five years from the last day that this Order is effective (including any renewals of this
Order); (b) store all such records in a manner accessible within a reasonable period of time; and (c) make such records available
to FinCEN, or any other appropriate law enforcement or regulatory agency, upon request, in accordance with applicable law.
E. No Effect on Other Provision of the BSA or Its Implementing Regulations
Nothing in this Order otherwise modifies or affects any provision of the BSA or the regulations implementing the BSA to the
extent not expressly stated herein.
F. Confidentiality
This Order is being publicly issued, and its terms are not confidential.
G. Compliance
The Covered Business must supervise, and is responsible for, compliance by each of its officers, directors, employees, and
agents with the terms of this Order. The Covered Business must transmit this Order to each of its agents located in the Covered
Geographic Area. The Covered Business must also transmit this Order to its Chief Executive Officer or other similarly acting
manager.
H. Penalties for Noncompliance
The Covered Business, and any of its officers, directors, employees, and agents, may be liable, without limitation, for civil
or criminal penalties for violating any of the terms of this Order.
I. Validity of Order
Any judicial determination that any provision of this Order is invalid shall not affect the validity of any other provision
of this Order, and each other provision shall thereafter remain in full force and effect. A copy of this Order carries the
full force and effect of an original signed Order.
J. Paperwork Reduction Act
The collection of information subject to the Paperwork Reduction Act contained in this Order has been approved by the Office
of Management and Budget (OMB) and assigned OMB control number 1506-0056. An agency may not conduct or sponsor, and a person
is not required to respond to, a collection of information unless it displays a valid OMB control number.
K. Questions
All questions about the Order should be directed to FinCEN at https://www.fincen.gov/contact.
(Authority: 31 U.S.C. 5326)
Dated: March 6, 2026. Andrea M. Gacki, Director, Financial Crimes Enforcement Network. [FR Doc. 2026-04641 Filed 3-9-26; 8:45 am] BILLING CODE 4810-02-P
Footnotes
(1) The Bank Secrecy Act, as amended, is codified at 12 U.S.C. 1829b, 1951-1960 and 31 U.S.C. 5311-5314, 5316-5336 and includes
other authorities reflected in notes thereto. Regulations implementing the BSA appear at 31 CFR chapter X. The Secretary of
the Treasury's authority to administer the BSA has been delegated to the Director of FinCEN. See Treasury Order 180-01 (Jan. 14, 2020).
(2) 31 U.S.C. 5326(a); see also 31 CFR 1010.370.
(3) 31 U.S.C. 5326(a).
(4) 31 U.S.C. 5326(d).
(5) Treasury Order 180-01 (Jan. 14, 2020).
(6) 31 CFR 1022.320.
(7) As of this date, the government is enjoined from applying the Geographic Targeting Order of March 14, 2025, to certain MSBs
in Texas. Thus, until the relevant injunctions are lifted, those MSBs are exempt from the definition of Covered Businesses
for purposes of the requirements of this Order.
(8) As of this date, the government is enjoined from applying the Geographic Targeting Order of March 14, 2025, to MSBs in Imperial
County and San Diego County. Thus, until that injunction is lifted, MSBs in these counties are exempt from the definition
of Covered Businesses for purposes of the requirements of this Order.
(9) To electronically file a Currency Transaction Report, a Covered Business will need a BSA E-Filing User account. To create
a BSA E-Filing User account, please visit https://bsaefiling.fincen.treas.gov/Enroll_Now.html. For more information on E-Filing, please visit https://bsaefiling.fincen.treas.gov/AboutBsa.html.
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