FinCEN Issues Modified Southwest Border Geographic Targeting Order
We previously published a blog on FinCEN’s Southwest Border Geographic Targeting Order (GTO): What Credit Unions Need to Know which required money services businesses (MSBs) operating near the southwest border in California and Texas to file Currency Transaction Reports (CTRs) with a reduced threshold from $10,000 to $200 for cash transactions. That GTO was in effect from April 14, 2025, through September 9, 2025. However, on September 8, 2025, FinCEN issued a revised Order which requires certain MSBs near the southwest border in Texas, California and now Arizona to file CTRs for cash transactions between $1,000 and $10,000 (increasing the threshold from the previously released March order). This blog will serve as an update on what has changed with respect to the new GTO, which supersedes the March 2025 GTO, and which is effective September 10, 2025, through March 6, 2026.
As noted in the new release, the revised GTO was designed to mitigate the burden on legitimate businesses while also combatting drug cartels and stopping the flow of deadly drugs into the United States, which is one of the Administration’s highest priorities. The number of counties covered under the GTO has also changed (see below for coverage locations). The new Order provides a 30-day compliance period for MSBs that were not required to report under the March GTO, meaning those MSBs will not need to begin filing reports until October 10, 2025. Lastly, for all MSBs required to report under the GTO, the filing deadline is extended from the standard 15 days for CTRs to 30 days, for the entire period of the new GTO.
Specifically, the new Order “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”
As noted in our previous blog, this Order is important for credit unions because many serve MSBs and, as a result, they must have internal controls in place to properly manage the additional BSA-related risk for money laundering and other financial crimes. Additionally, credit unions must have a clear understanding of MSBs’ operations to assess and mitigate any potential risks. Credit unions must also perform ongoing due diligence.
Additionally, the blog notes that if your credit union is located in, or is near, one of the listed zip codes, it may be helpful to stay vigilant. Credit unions in these areas may be more likely to face increased exposure to suspicious activity as individuals seeking to avoid detection due to the GTO may attempt to use credit unions for similar activities.
Resources:
News Release: https://www.fincen.gov/news/news-releases/fincen-issues-modified-southwest-border-geographic-targeting-order
Frequently Asked Questions: https://www.fincen.gov/system/files/2025-09/FAQs-FINAL-508C.pdf
