On March 11th, FinCEN issued a Geographic Targeting Order (GTO) to combat money laundering and other illicit activities of Mexico-based cartels along the southwestern border of the United States. This is one of the first major moves by the Trump Administration following Executive Order 14157: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists on January 20, 2025.
This particular GTO requires all money services businesses (MSBs) located in 30 ZIP Codes across California and Texas near the southwest border (Covered Businesses) to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000. The terms of the GTO are effective beginning April 14, 2025, and ending September 9, 2025.
If you are an MSB or have MSB customers in the impacted areas, this is something that may warrant an update to your risk assessment. You will also want to verify that your MSB customers are making procedural changes to comply with these requirements as part of your Enhanced Due Diligence processes.
Additionally, on March 24th, FinCEN released some Frequently Asked Questions related to the GTO. If you have impacted MSB customers, this might be a good tool to help them understand the requirements and why this is a big deal. The FAQs specify
A business that willfully violates a GTO (and any partner, director, officer, or employee thereof who willfully participates in the violation) may be liable for the following civil and criminal penalties:
- Civil Penalties: The greater of either (i) $71,545 or (ii) the amount involved in the transaction (up to $286,184). A separate penalty may be applied for each violation.
- Criminal Penalties: A fine of not more than $250,000 and/or imprisonment for not more than 5 years."
We covered it in-depth during our March AML/CFT Membership Group. Be sure to check out these membership groups to help you with your compliance efforts!
Published
2025/03/28
