Geographic Targeting Order for Minnesota
In case you missed it, FinCEN issued a Geographic Targeting Order (GTO) that requires banks and money transmitters located in Hennepin and Ramsey counties in Minnesota to maintain records and report certain information to FinCEN. While there are some exclusions, covered transactions are generally any funds transfer for which records are required to be retained under either 31 CFR1020.410(a) or 31 CFR 1010.410(e) (aka funds transfer logs for transactions of $3,000 or more), and for which a corresponding payment order or transmittal order is accepted by the Covered Business as an originator's bank or transmittor's financial institution.
Covered transactions are to be reported by the end of the month following the month in which the covered transaction took place. For example, covered transactions occurring in February must be reported to FinCEN by March 31st.
Covered businesses should report covered transactions to FinCEN using the Financial Industry (FI) Portal, available at fincen.gov/resources/financial-institutions. Please refer to the GTO for more specific filing instructions.
The GTO took effect on February 12, 2026, and runs through August 10, 2026.
Published 2026/02/17
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!