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ARTICLE · 15 SEPTEMBER 2026

Ninth Circuit Blocks FinCEN’s Border Geographic Targeting Order

Ballard Spahr LLP
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On July 13, a divided Ninth Circuit panel upheld a lower court order that barred enforcement of FinCEN’s border Geographic Targeting Order (“GTO”). The GTO would have forced money services businesses (“MSBs”) in 30 ZIP codes along the U.S.-Mexico border to report cash transactions of just over $200, a dramatic reduction from the longstanding $10,000 reporting threshold.

GlobalGovernment, Public Sector
Wilson Smerconish
Wilson Smerconish
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On July 13, a divided Ninth Circuit panel upheld a lower court order that barred enforcement of FinCEN’s border Geographic Targeting Order (“GTO”). The GTO would have forced money services businesses (“MSBs”) in 30 ZIP codes along the U.S.-Mexico border to report cash transactions of just over $200, a dramatic reduction from the longstanding $10,000 reporting threshold. The decision in Novedades Y Servicios, Inc. v. FinCEN, 181 F.4th 961, 967 (9th Cir. 2026) is a significant procedural check on the administration’s anti-cartel enforcement agenda.

Cartels as a National Security Priority

The Trump administration has repeatedly framed cartel-linked money laundering as a national security threat. On January 20, 2025 – the first day of his second term – President Trump issued an executive order designating certain international cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists. The order declared that cartels “present an unusual and extraordinary

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