On September 2, 2026, FinCEN updated its Frequently Asked Questions on the Geographic Targeting Order (GTO) requiring money services businesses (MSBs) located in certain ZIP Codes in New Mexico and Texas near the U.S. southwest border to report cash transactions of $1,000 or more with FinCEN. FinCEN renewed the GTO and is effective from September 3, 2026, through March 1, 2027.

MSBs that were not required to report under the GTO published by FinCEN on March 10, 2026, and that would be required to report under this GTO have until October 3, 2026, to comply with the terms of this GTO. In addition, the filing deadline for all reports filed under this GTO is 30 days after the date on which the transaction takes place, instead of the usual 15 days for CTRs

The FAQs were issued to assist Covered Businesses in complying with the GTO. FinCEN clarified that these FAQs are applicable only to the said GTO, as reissued, and should not be construed to apply to any FinCEN regulation or other order, including other GTOs.

The full FAQs can be found here.

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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