Banker's Compliance Consulting Blog

Geographic Targeting Order for Minnesota

Written by Amy Kudlacek | Feb 19, 2026 9:47:54 PM

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