On September 8, 2025, FinCEN reiisued a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. FinCEN previously issued a notice of a GTO requiring certain money services businesses along the southwest border to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions.
The modified GTO requires certain money services businesses to file Currency Transaction Reports with FinCEN for cash transactions between $1,000 and $10,000 occurring in specific counties and ZIP codes. The GTO covers the following geographic locations in Arizona, California, and Texas:
Santa Cruz County, Arizona
Yuma County, Arizona
California ZIP Codes (all within Imperial County): 92231, 92249, 92281, 92283
California ZIP Codes (all within San Diego County): 91910, 92101, 92113, 92117, 92126, 92154, 92173
Cameron County, Texas
El Paso County, Texas
Hidalgo County, Texas
Maverick County, Texas
Webb County, Texas
The new GTO is effective September 10, 2025, through March 6, 2026. The GTO provides a 30-day compliance period for MSBs that were not required to report under the March GTO, which will not need to begin filing reports until October 10, 2025. For all MSBs required to report under the GTO, the filing deadline is extended from the standard 15 days for Currency Transaction Reports to 30 days, for the entire period of the GTO.
Read FinCEN’s announcement here.
The full modified GTO is available here.