All in BSA

On April 16, 2025, FinCEN updated its set of FAQs regarding its updated Geographic Targeting Order involving certain money services businesses in California and Texas on the southwest border. On March 24, 2025, FinCEN issued a set of Frequently Asked Questions in relation to the March 11 GTO requiring all money services businesses located in 30 ZIP Codes across California and Texas to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000.

On April 2, 2025, U.S. Secretary of the Treasury Scott Bessent led a public-private partnership event with 16 systemically important global financial institutions and federal law enforcement agencies, focused on denying Iran access to the global financial system. This event is part of FinCEN’s “Iran Maximum Pressure and Counter Terrorism” (or IMPACT) Exchange series. 

On April 9, 2025, FinCEN issued a Financial Trend Analysis focused on patterns and trends identified in BSA data linked to fentanyl-related illicit finance. The BSA data filed between January and December 2024 included 1,246 reports identifying suspected fentanyl-related activity including precursor chemical procurement, fentanyl trafficking, and fentanyl-linked money laundering.

On April 1, 2025, FinCEN issued an Advisory to assist financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS). The Advisory outlines how ISIS funds itself through international support and various money transfer methods and also provides red flags for financial institutions to identify suspicious activity.

On March 31, 2025, FinCEN issued an Alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations (TCOs). The Treasury, alongside FinCEN, is urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by these Mexico-based criminal organizations.

On March 24, 2025, FinCEN issued a set of Frequently Asked Questions for the Geographic Targeting Order involving certain money services businesses in California and Texas on the Southwest Border. This is in relation to the March 11 GTO requiring all money services businesses located in 30 ZIP Codes across California and Texas to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000.

On March 11, 2025, FinCEN issued a notice of a Geographic Targeting Order 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. The order will take effect starting April 14, 2025 and ends on September 9, 2025.

On 2/27/25, FinCEN announced that it will not impose fines, penalties, or any other enforcement actions against companies that fail to file or update beneficial ownership information (BOI) reports under the Corporate Transparency Act by the current deadlines. In a news release, FinCEN stated that “no fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.”