What does FinCEN's 2026 Geographic Targeting Order for money services businesses along the southwest border require, who is covered, and for how long?
Covered money services businesses (MSBs) in the listed southwest border zip codes must file a Currency Transaction Report for each currency transaction of $1,000 or more, but not more than $10,000, and verify the identity of the person presenting it. The Order is effective September 3, 2026 and ends March 1, 2027 (91 FR 56776).
What the rule says:
- Covered: an MSB as defined in 31 CFR 1010.100(ff) located in the listed zip codes. These are associated with Cameron, El Paso, Hidalgo, Maverick and Webb Counties in Texas, and Bernalillo, Dona Ana and San Juan Counties in New Mexico. MSBs the government is enjoined by court order from applying the March 14, 2025 order to are excluded while the injunction remains in force (91 FR 56776).
- Covered transactions are each deposit, withdrawal, currency exchange or other payment or transfer by, through or to the business involving currency in that range. Transactions with a commercial bank need not be reported under the Order (91 FR 56776).
- File within 30 days after the transaction, e-filed through the BSA E-Filing System, with "MSB0926GTO" in Field 45 of Part IV. If you get a warning that the amount is below $10,000, ignore it and continue (91 FR 56776).
- Before concluding the transaction, follow 31 CFR 1010.312 and record the specific identifying information on the report. "Known customer" is not an acceptable notation. Armored car employees need not be identified (91 FR 56776).
Timing:
- Effective September 3, 2026; ends March 1, 2027. October 3, 2026 is the compliance date only for businesses not covered by the March 10, 2026 order.
- Keep reports and related records five years from the last day the Order is effective, including renewals. A GTO's maximum period is 180 days unless renewed (91 FR 56776).
What to do:
- Check each location's zip code against the Order's list, and confirm whether any injunction applies to you.
- Supervise compliance by your officers, directors, employees and agents. Send the Order to each agent located in the covered area and to your CEO or similarly acting manager (91 FR 56776).
When it becomes a SAR question: existing duties continue, including CTRs above $10,000 and SARs where appropriate. FinCEN encourages voluntary SARs on transactions conducted to evade the $1,000 threshold (91 FR 56776).
Sources
- Federal Register document 2026-18194: https://www.federalregister.gov/documents/2026/09/04/2026-18194/geographic-targeting-order-imposing-recordkeeping-and-reporting-requirements-on-certain-money
This answer is general information, not legal advice. Forteris is not a law firm.
Have a question this doesn't cover?
The Forteris Compliance Assistant answers your team's BSA/AML questions in Slack, from the same checked library, with every answer reviewed by Forteris before it is posted. Free for 14 days or 10 questions.