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FinCEN GTO Lowers CTR Threshold to $200 for MSBs

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 zip codes across California and Texas near the southwest border to file Currency Transaction Reports (CTRs) for currency transactions that exceed $200. The affected MSBs must also verify the identity of persons presenting such transactions.

Note, this only applies to MSBs and not credit unions or banks.

The order covers the following ZIP codes across seven counties in California and Texas:

  • Imperial County, California: 92231, 92249, 92281, 92283
  • San Diego County, California: 91910, 92101, 92113, 92117, 92126, 92154, 92173
  • Cameron County, Texas: 78520, 78521
  • El Paso County, Texas: 79901, 79902, 79903, 79905, 79907, 79935
  • Hidalgo County, Texas: 78503, 78557, 78572, 78577, 78596
  • Maverick County, Texas: 78852
  • Webb County, Texas: 78040, 78041, 78043, 78045, 78046

The GTO is intended to help combat illicit activities and money laundering by Mexico-based cartels along the southwest border of the United States. In January, President Trump issued an Executive Order creating a process by which certain cartels and other organizations would be designated as Foreign Terrorist Organizations (FTOs) and/or Specially Designated Global Terrorists (SDGTs). Since then, eight organizations have been designated as FTOs and SDGTs, including six major Mexico-based drug cartels.

The GTO is effective beginning 30 days after the date on which the order is published in the Federal Register. The terms are effective for 179 days thereafter.

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John Zasada
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John Zasada is a Principal in Doeren Mayhew's Financial Institutions Group, where he assists financial institutions in navigating regulatory compliance.

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