Understanding FinCEN’s Southwest Border Geographic Targeting Order for Money Service Businesses

Business, News

by | Mar 26, 2025

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Southwest Border Geographic Targeting Order (GTO) aimed at Money Service Businesses (MSBs)[1]. This order is designed to enhance the monitoring and reporting of currency transactions in specific geographic areas, particularly those along the southwest border of the United States. For an MSB, it is crucial to understand the implications of this order and how it (The Financial Crimes Enforcement Network, 2025) affects your operations.

Key Points for Money Service Businesses:

  1. Enhanced Reporting Requirements: MSBs operating in the targeted geographic areas are required to report currency transactions that meet certain criteria. This includes transactions involving amounts of $3,000 or more, whether conducted in a single transaction or multiple transactions over a short period.
  2. Geographic Scope: The GTO specifically targets areas along the southwest border, including parts of California, Arizona, New Mexico, and Texas. MSBs in these regions must be vigilant in their reporting practices to comply with the order.
  3. Compliance and Penalties: Failure to comply with the GTO can result in significant penalties, including fines and potential legal action. MSBs must ensure that their reporting systems are up-to-date and capable of capturing the required information.

What is Typically Required in a Currency Transaction Report by an MSB:

To comply with the GTO, MSBs must include specific information in their currency transaction reports (CTRs). This typically includes:

  • Customer Identification: Full name, address, and identification number of the individual conducting the transaction.
  • Transaction Details: Date, amount, and type of transaction (e.g., cash deposit, withdrawal, exchange).
  • Source and Destination of Funds: Information about where the funds are coming from and where they are going.
  • Purpose of Transaction: A brief description of the reason for the transaction, if known.

By understanding and adhering to these requirements, MSBs can ensure compliance with FinCEN’s Geographic Targeting Order and contribute to the broader effort to combat financial crimes in the targeted regions.  Our TALG team will continue to monitor the recent developments with FinCEN and will continue to keep you apprised.

[1] (The Financial Crimes Enforcement Network, 2025) 

 

Author

  • Ismail Amin

    Ismail’s legal experience encompasses serving Fortune 500 companies, mid-sized privately held companies, and entrepreneurs. He presently serves as Corporate and Litigation Counsel to large and mid-sized businesses throughout California, Nevada, Texas, North Carolina, and New York as well as General and Personal Counsel to high-profile hospitality operators in California and Nevada. Ismail’s practice emphasizes Business and Intellectual Property matters, with a focus on healthcare, biopharmaceuticals, biotechnology, and hospitality. Ismail has counseled the firm’s healthcare provider clients in acquiring or selling assets while maximizing return and minimizing risk. He has helped clients acquire or sell over $1 billion worth of healthcare-related assets, including hospitals.

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