Judge Blocks FinCEN’s Southwest Border GTO

On April 24, 2025, the San Diego Union-Tribune reported that a San Diego Judge blocked the FinCEN order to require money services businesses to report transactions above $200 but not more than $10,000, but only in seven San Diego County ZIP codes. On March 11, 2025, FinCEN issued the notice requiring certain money services businesses along the southwest border of the United States 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. 

According to the report, U.S. District Judge Janis Sammartino granted a restraining order after an owner of a money services business in one of the targeted ZIP codes filed a lawsuit arguing that the new reporting requirement would impose “crushing costs” on businesses like hers. The plaintiff argued in part that the rule violated the Fourth Amendment by “(sweeping) up information about countless everyday transactions” and that criminals could easily avoid the enhanced surveillance by using money services businesses in neighboring ZIP codes outside the targeting order. 

The restraining order blocks the government from enforcing the rule for at least 28 days in the 11 targeted California ZIP codes in San Diego and Imperial counties. The impacted ZIP codes in San Diego County covered downtown San Diego, Barrio Logan, Logan Heights, Mountain View and Southcrest, as well as portions of Clairemont and Mira Mesa. Most of the border region of San Ysidro and Otay Mesa was also covered, as was a northern portion of Chula Vista.

Read the San Diego Untion-Tribune’s report here.

VIDEO: Filing a CTR on an Entity

VIDEO: Filing a CTR on an Entity

FinCEN Updates its FAQs on the Southwest Border GTO