FinCEN’s Modified Geographic Targeting Order Strengthens US Border Anti-Money Laundering Controls

The Financial Crimes Enforcement Network (FinCEN) has reissued a modified Geographic Targeting Order (GTO) aimed at disrupting cartel operations, money laundering and criminal finance along the southwest border. The updated order reflects a recalibrated approach: tightening oversight of suspicious cash transactions while also reducing unnecessary burdens on legitimate businesses.

This GTO requires money services businesses (MSBs) operating in designated counties and ZIP codes across Arizona, California and Texas to file Currency Transaction Reports (CTRs) for cash dealings between 1,000 and 10,000 dollars. By lowering the reporting threshold in high-risk border regions, FinCEN ensures that law enforcement can better track illicit funds connected to drug trafficking, organised crime, and networks now formally recognised as Foreign Terrorist Organisations (FTOs) or Specially Designated Global Terrorists (SDGTs).

The modification follows a series of executive actions earlier this year that saw six Mexico-based cartels designated as both FTOs and SDGTs. These designations elevate cartel-related money laundering to the same national security priority as counter-terrorist financing, underscoring the government’s commitment to denying transnational criminal organisations access to the U.S. financial system.

In practical terms, MSBs covered by the March 2025 GTO will continue reporting under the new framework with extended deadlines, while newly covered firms are given a compliance period until 10 October 2025. The reporting window for all CTRs has been lengthened from 15 days to 30 days, recognising the operational challenges businesses face in high-volume, high-risk areas.

The targeted locations include key trafficking corridors: Santa Cruz and Yuma Counties in Arizona; Imperial and San Diego County ZIP codes in California; and Cameron, El Paso, Hidalgo, Maverick and Webb Counties in Texas. These are regions historically exploited by cartels to move bulk cash, a critical stage in the laundering cycle.

By combining geographic precision with structured reporting requirements, FinCEN is enhancing its ability to map cash movements, identify laundering typologies, and support joint investigations with law enforcement. For compliance officers and financial crime professionals, the order highlights the ongoing expectation that frontline MSBs act as an extension of the nation’s defences against money laundering, terrorism financing, and drug cartel activity.

Read the press release here.