FinCEN's new border targeting order drops the CTR trigger to $1,000 for some money transmitters
A FinCEN geographic targeting order, effective 3 September 2026 and running through 1 March 2027, requires money services businesses in listed ZIP codes in Texas and New Mexico to file currency transaction reports on cash transactions from $1,000 to $10,000.
A currency transaction report is normally a $10,000 event. In parts of Texas and New Mexico, for money services businesses, it is now a $1,000 one. FinCEN published a geographic targeting order on 4 September 2026 (91 FR 56776) that requires certain MSBs along the southwest border to report and record much smaller cash transactions, and to check identity before completing them.
The order took effect on 3 September 2026 and runs through 1 March 2027. Businesses that were not already covered by FinCEN's earlier order of 10 March 2026 have until 3 October 2026 to comply.
Who is covered
A Covered Business is "a money services business, as defined in 31 CFR 1010.100(ff), located in the Covered Geographic Area." The area is a list of ZIP codes in eight counties:
| State | Counties |
|---|---|
| Texas | Cameron, El Paso, Hidalgo, Maverick, Webb |
| New Mexico | Bernalillo, Dona Ana, San Juan |
The list is by ZIP code, and it's long: El Paso County alone has 144. Check the actual ZIP list in the order rather than assuming a whole county is in.
There is one carve-out. MSBs that the government is "enjoined by court order from applying the Geographic Targeting Order published by FinCEN on March 14, 2025" are excluded for as long as the injunction stays in force. The order notes that the government is currently enjoined as to certain Texas MSBs.
What they must do
A Covered Transaction is any "deposit, withdrawal, exchange of currency or other payment or transfer" involving currency of "$1,000 or more, but not more than $10,000." For each one, the business must:
- verify the customer's identity under 31 CFR 1010.312 before completing it, and record that information on the CTR (a bare notation such as "known customer" is prohibited);
- file a CTR through the BSA E-Filing System "within 30 days following the day on which the Covered Transaction occurred," entering "MSB0926GTO" in Part IV, Field 45; and
- keep records "for a period of five years from the last day that this Order is effective."
The order "does not alter any existing BSA obligation of a Covered Business." CTRs above $10,000 and SARs carry on as before. And a covered business does not have to file a GTO report on a covered transaction with a commercial bank.
What it could mean
The order is addressed to MSBs. If your bank or credit union serves MSBs with locations in these ZIP codes, it lands on your desk too.
Start with the customer list. Pull every MSB customer and every agent location you know of and match addresses against the ZIP codes in the order. Many of the El Paso County ZIP codes begin with 885 rather than 799, so a quick filter on the first three digits will miss some.
Then talk to those customers. An MSB that suddenly has to file a CTR on a $2,500 cash transfer may see customers split transactions or move to a competitor outside the zone. Either can show up in the cash patterns you see at your end. We'd expect your transaction monitoring to throw more alerts on these accounts over the next six months, and it helps to have documented why before the alerts start. A short note in each MSB customer's file confirming that you've asked about the GTO, and what the customer told you, is cheap and useful later.
The injunction carve-out makes this harder. Two MSBs on the same street could be under different rules, depending on whether a court order covers them. Ask, and write down the answer.
The six-month window is short. This order follows earlier GTOs that FinCEN published in March 2025 and March 2026, so we wouldn't plan on 1 March 2027 being the end of it.