ARTICLE · 18 MARCH 2025

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping And Reporting Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO)...

United StatesGovernment, Public Sector

Andres Fernandez

Gabriel Caballero Jr.

Eddie A. Jauregui

Catherine Yepes

Kristen Jimenez

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Highlights

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) to combat the illicit activities and money laundering of Mexico-based cartels, drug traffickers and other criminal actors along the Southwest U.S. border.
The Southwest GTO requires all money services businesses located in 30 ZIP codes along the Southwest border in California and Texas to file Currency Transaction Reports with FinCEN in connection with cash transactions valued at more than $200.
U.S. Treasury Secretary Scott Bessent cited deep concerns over significant risks to the U.S. financial system posed by cartels, drug traffickers and other criminal actors along the Southwest border as the basis for the Southwest GTO.

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