Southwest Border Crackdown: FinCEN’s $200 CTR Threshold Will Impact Nearly Every MSB Transaction — Here’s What You Need to Know

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a new Geographic Targeting Order (GTO) that will dramatically affect the day-to-day operations of Money Services Businesses (MSBs) located near the Southwest Border. (https://www.fincen.gov/news/news-releases/fincen-issues-southwest-border-geographic-targeting-order) This order, which takes effect April 14 and continues through September 9, requires MSBs operating in 30 designated ZIP codes across California and Texas to file Currency Transaction Reports (CTRs) for all currency transactions greater than $200 and not exceeding $10,000.

This change is not incremental. It will result in required CTR filings for the vast majority of customer transactions. In fact, depending on the nature of the MSB’s customer base, it is likely that between 90 to 95 percent of all daily transactions will now require a CTR under the GTO. That translates into a sudden, intensive reporting obligation that few MSBs are fully prepared for.

ComplyCheck is already working with impacted MSBs to bring them into compliance before the deadline. If your business falls within one of the designated ZIP codes, this is not a regulation you can afford to ignore. The penalties for noncompliance are steep, and the reporting workload will be considerable. Our team of compliance professionals is ready to help streamline the process, ensure accurate filings, and minimize your exposure to risk.

The Reason Behind the Order

This GTO is not a typical administrative update. It’s a calculated move in response to growing national security threats along the southern border. Following President Trump’s January 20 Executive Order 14157, which authorized the designation of major drug cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), the Department of the Treasury issued this order as part of a coordinated campaign to disrupt the financial lifelines of these criminal networks.

FinCEN’s order targets MSBs specifically because they often serve as entry points into the financial system for underbanked and cash-intensive populations—characteristics that make them vulnerable to exploitation by illicit actors. According to the government, the flow of narcotics, money laundering activity, and related criminal transactions in the affected counties justifies enhanced scrutiny. By lowering the reporting threshold to $200, regulators aim to gain visibility into patterns that would otherwise escape detection under the standard $10,000 threshold.

Covered Businesses and Geographic Scope

The GTO applies to MSBs operating in seven counties across California and Texas. These include Imperial and San Diego Counties in California, and Cameron, El Paso, Hidalgo, Maverick, and Webb Counties in Texas. The specific ZIP codes within these counties are explicitly listed in the order and the FAQs released by FinCEN.

Any business that meets the federal definition of a Money Services Business under 31 CFR 1010.100(ff) and operates within one of the designated ZIP codes is subject to the GTO. This includes check cashers, money transmitters, dealers in foreign currency, and other businesses providing traditional MSB services. The requirement to file CTRs applies only to currency transactions in connection with these specific MSB activities. Transactions outside the scope of money services—such as sales of goods—are not covered.

It’s important to note that the order does not change the general definition of an MSB, nor does it affect businesses that operate outside the listed ZIP codes. However, FinCEN has clarified that a business may be asked to provide documentation to demonstrate that it does not fall under the order if its location or operations are in question.

The Reporting Obligation

From April 14 through September 9, 2025, any MSB located in one of the designated ZIP codes must file a CTR for every cash transaction involving more than $200 but not exceeding $10,000. These CTRs must be submitted within 15 calendar days of the transaction date using the BSA E-Filing System.

The CTR must include the special keyword “MSB0325GTO” in Field 45, Part IV of the report. This identifier distinguishes GTO-related filings from standard CTR submissions and is a required component of compliance.

This obligation does not replace standard CTR requirements for transactions over $10,000, which still apply. Likewise, suspicious transactions at or above $2,000 must continue to be reported through Suspicious Activity Reports (SARs) under existing rules. FinCEN encourages businesses to also file SARs when they suspect that a customer is structuring transactions to avoid the $200 threshold introduced by the GTO.

While the order does not alter aggregation requirements, businesses must continue to aggregate currency transactions exceeding $10,000 as usual for traditional CTRs. For transactions that fall under the GTO’s $200–$10,000 threshold, each qualifying transaction must be reported individually, unless an existing aggregation rule under the BSA applies.

Compliance Realities for MSBs

The practical implications of this order cannot be overstated. For most MSBs in the affected areas, this will effectively turn CTR filing into a daily—or even hourly—task. Transactions that were previously routine, such as a $300 check cashing or a $500 remittance, will now each require a CTR. That means front-line staff will need to be trained to collect complete identification and transaction details for every qualifying customer interaction, ensuring that each CTR submission meets the technical and regulatory standards required by FinCEN.

Adding to the challenge is the narrow 15-day window for filing, which leaves little room for error. Missed filings, incomplete reports, or failures to apply the proper “MSB0325GTO” identifier can all result in serious compliance violations. According to FinCEN, civil penalties for willful violations can exceed $286,000 per incident, and criminal penalties include fines of up to $250,000 and up to five years in prison.

Additionally, MSBs must retain all records related to the GTO—including filed CTRs and any supporting documentation—for a minimum of five years from the final day the GTO is in effect, even if the order is not renewed. These records must be maintained in a way that allows for timely production in the event of an audit or law enforcement inquiry.

Why the Stakes Are So High

While this GTO is geographically limited, its implications extend far beyond California and Texas. It represents a shift in how FinCEN is likely to handle emerging threats tied to specific regions and activities. If successful, this model may be replicated in other high-risk areas, especially where narcotics trafficking, unregistered MSB activity, or smurfing is suspected.

MSBs across the country should see this order as a sign of things to come. Enhanced scrutiny, targeted orders, and rapid implementation timelines are increasingly becoming the norm. The ability to adapt quickly — operationally and procedurally — will be a hallmark of well-run compliance programs going forward.

How ComplyCheck Can Help

At ComplyCheck, we understand that most MSBs don’t have the time or resources to overhaul their reporting systems overnight. That’s why we’ve developed a comprehensive, turn-key support model specifically for businesses impacted by the March 2025 GTO. Whether you need help identifying whether your business falls under the order, or you need full-service CTR filing support, we have the expertise to guide you through.

Our team includes former BSA Officers, and MSB operators. We’re not just consultants—we’re operational partners who know how to implement practical, regulator-ready solutions that make sense for your business. We can assist with identifying your risk exposure, enrolling in or optimizing your use of the BSA E-Filing System, building a GTO-specific workflow, and training your staff to ensure every report is accurate, timely, and compliant.

This isn’t the time to wait and see. The GTO is already active, and the window for noncompliance is closing fast. If your business is operating in a covered ZIP code—or even adjacent to one—reach out to us today.

Final Thoughts

The March 11 GTO is not a theoretical rule change. It is an urgent regulatory action with immediate consequences. For MSBs located along the Southwest Border, it will result in a near-universal CTR filing requirement that touches nearly every cash transaction conducted in the normal course of business.

Failing to act now is not just a compliance risk—it’s a business risk. Don’t let your MSB be caught off guard. Contact ComplyCheck today to get the systems, processes, and training in place before the first CTR is due.

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