Q1: What is the recent FinCEN GTO affecting MSBs in California and Texas?
FinCEN issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 ZIP codes near the southwest border of California and Texas to file Currency Transaction Reports (CTRs) for all cash transactions exceeding $200.
Q2: Why is this GTO significant?
The $200 threshold is a dramatic departure from the usual $10,000 threshold for CTR filings, substantially increasing compliance burdens for MSBs operating in those regions.
Q3: Has the GTO been paused or lifted?
No, the GTO remains in effect. However, in April 2025, a Temporary Restraining Order (TRO) was granted by a federal judge that exempts 11 MSBs along the Texas border. This TRO applies only to the named plaintiffs in the legal action and does not constitute a blanket exemption for other MSBs operating in the same ZIP codes.
Q4: If my business operates in one of these ZIP codes, am I exempt if I wasn’t part of the lawsuit?
No. Unless your business has been granted a specific legal exemption, such as a TRO by a court, you are still required to comply with the GTO and must file CTRs for applicable transactions.
Q5: What are the possible business impacts of the GTO?
Some common impacts reported by MSBs include:
- Increased business expenses (staff training, software purchases, etc.)
- Transaction volume shifts, either decreases in impacted areas or increases in nearby non-impacted ZIP codes
- Cessation of operations in affected ZIP codes due to cost or risk
- Increased compliance staffing or need to outsource compliance operations
- Customer confusion or loss due to enhanced reporting burdens
Q6: What should MSBs do if they are impacted by this GTO?
MSBs should:
- Conduct a ZIP code impact assessment.
- Update internal policies and procedures to reflect the $200 CTR threshold.
- Train staff accordingly.
- Evaluate operational costs and compliance burdens.
- Consider seeking legal counsel if they wish to explore exemption options through litigation or TROs.
- Stay informed through industry associations or legal updates regarding ongoing legal challenges.
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This page was last updated on May 11, 2025.
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