On September 2, FinCEN announced that it had reissued a geographic targeting order (GTO) requiring certain money services businesses located in certain ZIP codes in eight counties along the U.S.-Mexico border to file Currency Transaction Reports (CTRs) for cash transactions between $1,000 and $10,000. The GTO covers businesses in Cameron, El Paso, Hidalgo, Maverick, and Webb counties in Texas, and Bernalillo, Dona Ana, and San Juan counties in New Mexico. The order, issued under the BSA, is effective September 3 through March 1, 2027, and requires covered businesses to verify the identity of persons conducting certain transactions and to retain all related records for five years. Businesses that were not covered under the prior order published on March 10 have until October 3 to comply.

The GTO does not alter existing BSA/AML obligations. Rather, covered businesses must continue to file CTRs for currency transactions of $10,000 or above and Suspicious Activity Reports where appropriate. FinCEN noted that, as previously covered by InfoBytes, certain money services businesses in Texas that are subject to a court injunction barring enforcement of the prior March 14, 2025, order (covered here) remain exempt from the definition of covered businesses under this reissuance. The order carries civil and criminal penalties for noncompliance by covered businesses and their officers, directors, employees, and agents.