What You Need to Know About the March 2025 Geographic Targeting Order
If your money services business operates in specific areas along the U.S.-Mexico border, you need to be aware of new temporary reporting requirements that take effect on April 14, 2025.
What Is This Order?
The Financial Crimes Enforcement Network (FinCEN) has issued a Geographic Targeting Order (GTO) that requires certain money services businesses to report transactions that would normally fall below standard reporting thresholds. This is part of ongoing efforts to combat illicit finance by drug cartels and other criminal organizations along the southwest border.
Does This Apply to Your Business?
Geographic Coverage This order applies to MSBs located in the following areas: California: • Imperial County: ZIP codes 92231, 92249, 92281, 92283 • San Diego County: ZIP codes 91910, 92101, 92113, 92117, 92126, 92154, 92173 Texas: • Cameron County: ZIP codes 78520, 78521 • El Paso County: ZIP codes 79901, 79902, 79903, 79905, 79907, 79935 • Hidalgo County: ZIP codes 78503, 78557, 78572, 78577, 78596 • Maverick County: ZIP code 78852 • Webb County: ZIP codes 78040, 78041, 78043, 78045, 78046
What Transactions Are Covered?
You must report any deposit, withdrawal, currency exchange, or other payment or transfer involving currency amounts between $200.01 and $10,000. This is significantly lower than the standard $10,000 CTR threshold you're already familiar with.
What You Need to Do
1. File Currency Transaction Reports (CTRs) For each covered transaction, you must: • File a CTR within 15 days of the transaction • Submit electronically through the BSA E-Filing System • Enter "MSB0325GTO" in Field 45 (Part IV) of the CTR Important Note: The system may give you a warning that the transaction is below $10,000. Ignore this warning and continue with your submission. 2. Verify Customer Identity Before completing any covered transaction, you must: • Follow the standard identification requirements (31 CFR 1010.312) • Record specific identifying information on the CTR (driver's license number, account number, etc.) • You cannot simply write "known customer" or "bank signature card on file" 3. Keep Records All reports and related records must be: • Retained for five years after the order expires • Stored in an easily accessible format • Made available to FinCEN or law enforcement upon request
Exceptions
You do NOT need to file reports for: • Transactions between your MSB and a commercial bank • Transactions with armored car service employees (no identification required) • U.S. Postal Service only: Payments made solely for postage or philatelic products
Important Timeline
Effective Date: April 14, 2025 Expiration Date: September 9, 2025 Duration: 180 days (may be renewed)
Your Other BSA Obligations Remain Unchanged
This order does not replace your existing Bank Secrecy Act responsibilities: • Continue filing standard CTRs for transactions over $10,000 • Continue filing Suspicious Activity Reports (SARs) as required • Maintain all other BSA compliance procedures Pro Tip: FinCEN encourages you to voluntarily file SARs when you notice transactions that appear designed to evade the $200 reporting threshold.
Compliance Is Critical
Your business is responsible for ensuring that all officers, directors, employees, and agents comply with this order. You must: • Share this order with your CEO or senior manager • Distribute it to all agents in the covered geographic areas • Implement proper supervision and training Warning: Failure to comply can result in civil and criminal penalties for your business and individual staff members.
Need Help?
If you have questions about this Geographic Targeting Order or need assistance with BSA compliance: • Visit FinCEN's website • Access the BSA E-Filing System • Consult with your compliance officer or legal counsel
Questions to Ask Yourself
✓ Is my business located in one of the covered ZIP codes? ✓ Have I updated my transaction monitoring systems? ✓ Have I trained my staff on the new $200+ reporting threshold? ✓ Do I have processes in place to file CTRs within 15 days? ✓ Have I shared this order with all relevant personnel?
Stay compliant, stay informed, and reach out to your compliance team if you need any clarification on these new requirements.
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