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The GTO requires all money services businesses located in 30 ZIP codes across California and Texas near the southwest border to file Currency Transaction Reports with FinCEN at a $200 threshold, in connection with cash transactions.
Source: Financial Crimes Enforcement Network
Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published responses to frequently asked questions about a Geographic Targeting Order (GTO), issued March 11, to further combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States. The GTO requires all money services businesses located in 30 ZIP codes across California and Texas near the southwest border to file Currency Transaction Reports with FinCEN at a $200 threshold, in connection with cash transactions.
One example of the questions answered:
Question 13: “What are the penalties for violating the GTO?
As of March 14, 2025, a business that willfully violates a GTO (and any partner, director, officer, or employee thereof who willfully participates in the violation) may be liable for the following civil and criminal penalties:
- Civil Penalties: The greater of either (i) $71,545 or (ii) the amount involved in the transaction (up to $286,184).24 A separate penalty may be applied for each violation.
- Criminal Penalties: A fine of not more than $250,000 and/or imprisonment for not more than 5 years.25
24 31 U.S.C. 5321(a)(1); 31 CFR 1010.821; FinCEN, Inflation Adjustment of Civil Monetary Penalties, 90 FR 5629 (Jan. 17, 2025).
25 31 U.S.C. 5322; 31 CFR 1010.840.
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