FinCEN expands GTO with $1,000 CTR threshold in border counties
Covered MSBs must apply $1,000 CTR reporting in named border areas
Change
FinCEN expanded a Geographic Targeting Order requiring covered MSBs to file CTRs for $1,000–$10,000 cash transactions in specified southwest-border counties and ZIP codes through September 2, 2026.
Why it matters
The expanded GTO creates a lower CTR filing trigger for covered MSBs operating in named areas of Arizona, California, New Mexico and Texas. Cash transactions between $1,000 and $10,000 must be identified against the covered geography and reported during the GTO period. Newly covered MSBs receive until April 6, 2026 to begin filing, while all covered MSBs use a 30-day CTR filing deadline through September 2, 2026.
Implications
- — Covered MSBs must identify cash transactions between $1,000 and $10,000 in the specified counties and ZIP codes — the GTO lowers the CTR reporting trigger for those locations.
- — BSA/AML reporting teams at covered MSBs must apply the 30-day CTR filing deadline during the March 7–September 2, 2026 GTO period — the order replaces the standard 15-day deadline for covered reports.
- — Newly covered MSBs must begin filing required CTRs by April 6, 2026 — the 30-day compliance period applies only to MSBs not covered by the September 2025 GTO.
Who is affected
- — Money services businesses operating in covered counties and ZIP codes
- — BSA/AML reporting teams at covered MSBs
What to watch
- — April 6, 2026 — newly covered MSBs must begin filing required CTRs.
- — September 2, 2026 — expanded GTO period ends unless FinCEN extends or replaces the order.