New Geographical Targeting Order: Additional Recordkeeping and Reporting Requirements on Money Service Businesses Along the Southwest Border

On April 14, 2025, FinCEN implemented a Geographical Targeting Order (GTO) in parts of Texas and California along the southern U.S. border with Mexico. Announced on March 11, 2025, this GTO had a very short lead time, impacting financial institutions significantly.

Which Financial Institutions Will be Affected?

This new requirement affects Money Services Businesses (MSBs) in specified zip codes, mandating additional customer information collection, such as names, birthdates, identification numbers and proof of identification. Consequently, the workload for data collection and the number of Cash Transaction Reports (CTRs) will increase substantially.

How Your MSB Can Comply

The good news is that NICE Actimize has enhanced its CTR offering, providing more coverage for organizations to comply with the April deadline. As always, we continue to monitor regulatory changes to ensure we have solutions that can meet customer needs in a short period of time, even if it’s a GTO with only 34 days of advanced notice.

GTOs are not new, first introduced by FinCEN in 2016. The orders typically last for 180 days, but as seen in the past, are often renewed.  It is also possible that the GTO can be modified or expanded to include additional border counties.

The latest GTO targets low-value cash transactions of over $200 through MSBs. Currently, Financial Institutions must report cash transactions over $10,000 in a single day to FinCEN, a threshold set by the Bank Secrecy Act in 1970. Despite inflation, this threshold remains unchanged, equivalent to about $82,000 today. Raising this threshold has been discussed, which could enable more significant money laundering activities.

Looking Ahead

Industry discussions around the latest GTO focus on the low dollar amount and FinCEN’s capacity to handle the increased volume of CTRs. Each CTR filed under GTO guidelines will include an identifier (Field 45), aiding FinCEN in tracking these transactions. While law enforcement isn’t focused on $200 transactions, this will help follow the money. Technological advancements will enable FinCEN to identify network activity and trace transactions supporting the drug trade.

To learn more about the details of this GTO  view our recent overview.

Streamlining Existing CTR Processes

The filing of regulatory reports when done manually can be both time consuming and error-prone. Outdated legacy systems and labor-intensive processes limit teams in their ability to act quickly and accurately, a hindrance when dealing with changing regulations, such as the most recent GTO.

NICE Actimize’s CTR Processing and Automation provides flexible, automated CTR filing for financial institutions.

Gain access to:

• Streamlined data aggregation and management
• Robust, flexible CTR detection capabilities
• Automated CTR generation and validation
• Seamless CTR e-filing prepares, files, and tracks filing status
• Comprehensive workflow management for process consistency

Discover how CTR Processing & Automation can improve your compliance program with a personalized demo.