Cash of $1,000 is enough for a currency transaction report at money services businesses in listed ZIP codes of eight Texas and New Mexico counties until 1 March 2027. Everywhere else the line is over $10,000. FinCEN set that line when it reissued its southwest border GTO on 2 September 2026 (91 FR 56776). For one place and one period, a GTO moves the line a transaction monitoring program watches.
What is a geographic targeting order, and what does GTO stand for?
GTO stands for geographic targeting order, the full form FinCEN (the Financial Crimes Enforcement Network) uses in banking and finance. Under the Bank Secrecy Act (BSA), when "reasonable grounds exist for concluding that additional recordkeeping and reporting requirements are necessary", Treasury may order financial institutions or nonfinancial businesses "in a geographic area" to keep records of, and report, transactions at or above an amount it sets (31 U.S.C. 5326(a); 31 CFR 1010.370).
No order "shall be effective for more than 180 days unless renewed" (5326(d)). The order is an AML and CFT measure that sits on top of the standing reports in the AML rules in the United States. Outside AML the letters have other expansions, and geographic targeting in advertising means showing ads by area; in AML, finance and banking, in English or in Hindi, GTO means the FinCEN order.
How does a geographic targeting order work, and how is it renewed?
An order comes about in four steps:
- A request or Treasury's own initiative. Federal or state law enforcement asks, or Treasury acts alone; the power has been delegated to FinCEN's Director.
- The finding. "Reasonable grounds" show the extra reporting is needed to carry out the BSA or stop its evasion.
- The terms. Who, which transactions, the amount, the form and the deadline.
- Renewal. After 180 days the order lapses unless renewed. FinCEN has reissued the border order three times, each time with changes.
The standing duties stay in place: covered businesses still file CTRs above $10,000 and SARs where appropriate.
Which GTOs are in effect, which geographical areas are covered, and at what threshold?
Table 1. Geographic targeting orders, status as of 23 October 2026.
| Order | Who reports | Line | Area | Period | Status |
|---|---|---|---|---|---|
| Southwest border GTO (91 FR 56776) | Money services businesses in listed ZIP codes | Cash of $1,000 to $10,000; CTR within 30 days | Cameron, El Paso, Hidalgo, Maverick and Webb counties, Texas; Bernalillo, Dona Ana and San Juan counties, New Mexico | 3 September 2026 to 1 March 2027 | In force |
| Earlier border GTOs (90 FR 12106, 90 FR 43557, 91 FR 11456) | Money services businesses | Cash of more than $200 to $10,000; from 10 September 2025, $1,000 to $10,000 | 30 ZIP codes in seven California and Texas counties; later versions added Arizona and New Mexico counties | 14 April 2025 to 2 September 2026 | Ended |
| Minnesota GTO (91 FR 51588) | Banks and money transmitters with a branch, subsidiary or office in Hennepin or Ramsey County | Funds transfers of $3,000 or more to a recipient abroad | Senders giving an address in either county | 11 August 2026 to 6 February 2027 (first order from 12 February 2026) | In force |
| Residential real estate GTOs (FinCEN release, 9 October 2025) | US title insurance companies | Non financed home purchases through shell companies; $300,000 threshold, $50,000 in Baltimore | Counties and metropolitan areas in 13 states and the District of Columbia | Last renewed from 10 October 2025 | Expired 28 February 2026 |
| Los Angeles Fashion District GTO (FinCEN release, 2 October 2014) | Trades and businesses in the district | Cash of at least $3,000 | The Fashion District, Los Angeles | From 9 October 2014, for 180 days | History |
Two orders are in force. The September 2026 reissue lists no Arizona county and no California ZIP code, though the March 2026 version listed both. The Minnesota order, aimed at laundering tied to government benefits fraud, covers funds transfers abroad instead of cash (FinCEN renewal release, 7 August 2026).
What came after the residential real estate GTOs?
Those orders made title insurance companies identify the beneficial owners (UBOs) behind shell companies buying homes without a mortgage. FinCEN let them expire on 28 February 2026 "in light of" its Residential Real Estate Transfers rule (RRE rule), published 29 August 2024.
On 19 March 2026 a federal court in Texas vacated that rule (Flowers Title Companies v. Bessent). FinCEN appealed. The Fifth Circuit appeal is still open, and while the court's order stands, reporting persons "are not required to file Real Estate Reports" (FinCEN's RRE rule page).
Who does a GTO affect, and what are its requirements and reporting obligations?
A GTO affects only the businesses its text names. Under the border order these are money services businesses (MSBs) located in the covered ZIP codes, the U.S. Postal Service included, except for sales of postage or philatelic products. Under the Minnesota order they are banks and money transmitters with an office in the two counties.
A covered MSB on the border files a CTR within 30 days of each covered cash transaction, with "MSB0926GTO" in Field 45. Before it completes the transaction, it verifies and records the customer's identity. It keeps the records for five years from the order's last day and sends the order to its agents in the area. Minnesota works differently. Its filers send a CSV file through FinCEN's portal by the end of the month after each transfer.
Ufuk Gürdaş, the entry's reviewer, on which address counts: "The address that decides the line is not the same in every order: the border GTO turns on the ZIP code where the money services business or its agent handles the cash, the Minnesota GTO on the address the sender gives, so a rule keyed to the wrong address field files the wrong reports."
In complead, formerly Sanction Scanner, the transaction monitoring software scopes a rule per jurisdiction and backtests it against real history before it goes live; a compliance officer reviews each alert.
Does a GTO make a business add up small cash transactions?
FinCEN's own example: a $950 check cashed and $950 in foreign currency exchanged in one sale need no GTO report, because each is under $1,000 and "aggregation is not required at that amount" (border GTO FAQs, FAQ 14). Cash above $10,000 still adds up. If one person exchanges $5,000 inside the area and $6,000 outside on the same day, the MSB files a GTO CTR plus a regular currency transaction report, or one combined CTR with the GTO keyword (FAQ 9).
What are the criticisms of GTOs, and what have the courts done?
The objections are to process and burden. An order takes effect on FinCEN's own finding, and the September 2026 notice invites no public comment. At $1,000, a covered MSB files a CTR and verifies identity on cash that sits far below the usual $10,000 line. Challenges reached the courts: footnote 7 of the September 2026 order says the government is enjoined from applying the March 2025 order to certain Texas MSBs, which stay exempt while the injunctions stand.
FinCEN encourages voluntary SARs on cash split to evade the $1,000 line, a form of structuring. A GTO report is due on the amount alone, while a suspicious activity report rests on the filer's judgment that the activity is suspicious.
What happens when a business does not comply with a GTO?
On 31 March 2022 FinCEN assessed a $275,000 penalty against A&S World Trading, a business covered by the Los Angeles Fashion District order that failed to report more than $2 million in currency transactions. FinCEN called it its "first enforcement action for failing to comply with a Geographic Targeting Order" (FinCEN release, 1 April 2022).
A willful violation can bring a civil penalty of up to $71,545 or the amount involved, whichever is greater, with the amount capped at $286,184, and a separate penalty may apply to each violation (31 U.S.C. 5321(a)(1)). Criminal liability under 31 U.S.C. 5322(a), in its basic form, means prison for not more than five years, a fine of not more than $250,000, or both (FAQ 21).
The current border order ends on 1 March 2027. Unless FinCEN renews or reissues it, MSBs in the listed ZIP codes go back to the $10,000 CTR line after that date.
Related terms
- Transaction monitoring. Watching customer activity for laundering.
- Currency transaction report. The report on cash above $10,000 a business day.
- Structuring. Breaking cash under a reporting line on purpose.
- Suspicious activity report. Filed on a judgment of suspicion.
- Real estate fraud. Deception that takes money or title in a property deal.
