FinCEN Extends and Expands SW Border GTO for MSBs

Adam Witmer
BSA, Regulatory Update

On March 10, 2026, FinCEN issued a new Geographic Targeting Order (GTO) imposing recordkeeping and reporting requirements on certain money services businesses (MSBs) along the southwest border. The GTO effectively extends a similar order issued on September 10, 2025 and expired on March 6, 2026.

The GTO T requires 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. The new GTO also expands the "Covered Geographic Area" to add three counties in New Mexico, including Bernalillo, Dona Ana, and San Juan counties.

The GTO took effect on March 7, 2026 while the compliance date for persons that were not covered under the September 10, 2025 GTO be on April 6, 2026.

The Order can be found here.

Adam Witmer
BSA, Regulatory Update
Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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