Following the March 6 renewal and modification of a geographic targeting order (GTO), the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has released a series of frequently-asked questions to clarify the GTO’s scope and regulatory requirements.
The GTO requires certain money services businesses (MSBs) located in certain counties and ZIP Codes in Arizona, California, New Mexico and Texas near the southwest border to file additional currency transaction reports (CTRs) with FinCEN. These CTRs are required to be filed for cash transactions of $1,000 or more.
The terms of the GTO are effective through Sept. 2. However, MSBs that were not required to report under the GTO published by FinCEN on Sept. 10, 2025, have until April 6 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.
To assist covered businesses in complying with the GTO, FinCEN is disseminating a comprehensive list of FAQs, which are applicable only to this GTO, as reissued, and should not be construed to apply to any FinCEN regulation or other order, including other GTOs.
- What is a GTO? A GTO is an order issued by 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. To issue a GTO, FinCEN must reasonably conclude that the additional requirements are necessary to carry out the purposes of the BSA or prevent evasions thereof.A GTO may not exceed 180 days, but may be renewed as necessary.
- Why did FinCEN issue the GTO? Combatting drug cartels and halting the flow of dangerous drugs into the United States is a key priority for the Trump administration. On Jan. 20, 2025, President Donald Trump signed Executive Order 14157, which allows certain cartels and organizations to be labeled as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). On Feb. 20, 2025, the U.S. Departments of the Treasury and State identified eight entities, including six major drug cartels from Mexico, for these designations. This enables the U.S. to restrict their access to the financial system. The GTO aims to help counter drug trafficking and transnational crime. It addresses money laundering risks in areas where drug cartels operate, supporting law enforcement investigations related to these activities.
- What does the GTO require covered businesses to do? The GTO is effective from March 7, 2025, to Sept. 2. It allows a 30-day compliance period for certain MSBs, which do not need to start filing reports until April 6. The report filing deadline for all MSBs is extended from 15 days to 30 days for this period. Covered transactions involve amounts from $1,000 to $10,000. The GTO does not change existing BSA obligations, so covered businesses must still file CTRs for transactions exceeding $10,000 in value and SARs as required. FinCEN encourages voluntary SARs to report attempts to evade the GTO's thresholds.
The full list of FAQs can be found at www.fincen.gov/system/files/2026-03/SWB-GTO-FAQs.pdf.