FinCEN GTO Update

Geographic Targeting Orders or “GTOs” have been in the news a lot lately – although you may not hear them referred to as such. Sometimes you’ll see headlines like: “Treasury Targets Southwest Border Money Transfers,” “Treasury Expands Scrutiny of All-Cash Luxury Home Purchases in Key Markets,” or “Geo-Coordinates Locked In.” If you look behind the sensational headlines, you’ll often find a GTO.

So, what exactly is a GTO? 
    
A GTO is an order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act (BSA) that imposes additional recordkeeping or reporting requirements on domestic financial institutions or other businesses in a specific geographic area.

FinCEN will issue a GTO when the Secretary of the Treasury, acting through the Director of FinCEN, determines that there are reasonable grounds to believe additional BSA recordkeeping and reporting are necessary to further the objectives of the Act - such as combating money laundering, terrorist financing, or financial fraud - or to prevent evasion of those requirements. A GTO may not exceed 180 days, but may be renewed when deemed necessary. GTOs are authorized under 31 U.S.C. § 5326 and 31 C.F.R. § 1010.370.

Currently Active GTOs

In early 2026, GTOs are targeting government benefits fraud in Minnesota; money services businesses (MSBs) along the Southwest Border of the United States; and high-end non-financed (all-cash) real estate purchases in several major metropolitan areas. Here’s a snapshot of where these GTOs currently stand.

Government Benefits Fraud GTO -- Effective February 12, 2026 – August 10, 2026, unless renewed

Starting with the most recent development, FinCEN announced a GTO on January 9, 2026 to combat suspected federal government benefits fraud in Minnesota. The order applies to “banks” (and credit unions) and money services businesses with a branch, subsidiary, or office located in Hennepin County and Ramsey County, which covers Minneapolis and St. Paul, MN. The GTO was published in the Federal Register on January 13, 2026. FinCEN also issued Frequently Asked Questions (FAQs) on the new GTO, available here.

Effective February 12, 2026, the GTO requires institutions located in the above-named Minnesota counties to record and report certain international “funds transfers” of $3,000 or more if the:

•    Originator/transmittor provides an address in the covered geographic area (Hennepin County and Ramsey County, MN)
•    Originator/transmittor is not a publicly traded company on an SEC-regulated exchange 
•    Originator/transmittor is not a financial institution subject to anti-money laundering (AML) requirements under the BSA; and
•    Beneficiary/recipient is located outside the U.S. or uses a foreign financial institution to receive funds outside of the United States

Institutions must report all of the information required to be retained for BSA funds transfer recordkeeping purposes [31 CFR 1020.410(a)(1) and (2)] plus additional details, e.g., the beneficiary/recipient’s name, address, date of birth, phone number, email, and whether the source of funds for the transfer included any payments derived from any federal, state, or local government contract or benefit program. See FinCEN FAQ #6 for a full list of what must be reported.

The reports must be filed with FinCEN via the Financial Industry (FI) Portal (accessible at https://fiportal.fincen.gov) by the end of the month following the month in which the covered transaction took place (e.g., for a transaction occurring any day in March of 2026, a covered credit union would file a report with FinCEN by April 30, 2026). After logging in, filers must select “File Exchange,” then “Special Measures” as the Type of File and enter “FIN-62904-L4N7T” as the FinCEN Reference Number. See FinCEN FAQ #10. Records must be retained for five years from the expiration date of the GTO.

Note that FinCEN also issued an Alert (FIN-2026-Alert001) to urge financial institutions to identify and report fraud associated with Federal child nutrition programs in Minnesota.

Southwest Border GTO (Renewed) -- In force until March 6, 2026, unless further renewed

FinCEN issued the initial Southwest Border GTO on March 11, 2025. This order required MSBs in 30 ZIP codes across California and Texas along the Southwest border to file Currency Transaction Reports (CTRs) and retain records of cash transactions of more than $200 but not more than $10,000, and to verify the identity of persons conducting these transactions. This initial order was effective from April 14, 2025, to September 9, 2025. We covered this order in detail last March: FinCEN’s Southwest Border Geographic Targeting Order (GTO): What Credit Unions Need to Know | America's Credit Unions

FinCEN renewed the GTO with updated terms on September 8, 2025, effective from September 10, 2025 to March 6, 2026, unless further renewed. This order extended the enhanced reporting requirements to certain Arizona MSBs operating near the Southwest border. See also: FinCEN Issues Modified Southwest Border Geographic Targeting Order | America's Credit Unions

Residential Real Estate GTO (Renewed) – In force until February 28, 2026

This GTO requires U.S. title insurance companies in high-risk jurisdictions—including designated metropolitan areas and counties across California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia—to collect and report detailed information on non-financed residential real estate purchases made via shell companies or legal entities at or above a $300,000 threshold (and $50,000 in Baltimore City/County). The initial order was effective April 14, 2025 to September 9, 2025, and later extended from October 10, 2025 to February 28, 2026.

Transactions falling under the GTO are all-cash or equivalent payments involving legal entities—not publicly traded—and the reporting must include the identity of the individual representing the purchasing entity and all beneficial owners with 25% or greater ownership, along with government-issued ID, submitted via CTRs within 30 days of closing, identifying the legal entity, beneficial owners, and the individual representing the entity.

FinCEN will be transitioning to the Anti-Money Laundering (AML) Regulations for Residential Real Estate Transfers Rule (RRE Rule), effective March 1, 2026 (postponed from December 1, 2025) after the GTO expires on February 28th. The RRE Rule targets non-financed transfers of residential real estate to entities or trusts—not typical mortgage transactions. It applies when: (i) there's no mortgage from an AML- compliant lender, or (ii) the financing comes from a seller or nonregulated lender. The rule requires BSA reporting by “persons involved in real estate closings and settlements,” for example, title agents, settlement agents, escrow agents, or attorneys. Click here for more information.

This blog post is just a snapshot of current GTOs. Be sure to visit fincen.gov for more information.  

Questions? Suggestions for future blog posts? Contact the Compliance Team at compliance@americascreditunions.org.