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FinCEN Issues Southwest Border Geographic Targeting Order

FinCEN Issues Southwest Border Geographic Targeting Order

CRC
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March 13, 2025

Background:

As some of you may know, the Trump Administration has recently identified and designated specific Mexican cartels as Foreign Terrorist Organizations (FTOs) and/or Specially Designated Global Terrorists (SDGTs). With that, there are sanctions that were put in place that prohibit from U.S. businesses conducting business with these groups.

Current Update:

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to further combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States.

Some important points included in the order of important focus:

  • It affects all Financial Institutions in California and Texas near the southwest border regions but mainly money services businesses (MSBs) which are deemed higher risk.
  • The order identified 30 zip codes in these areas. Please see the order in the link below to identify these localities.
  • For these areas, the Currency Transaction Reports (CTRs) filings with FinCEN were reduced to a $200 threshold for cash transactions.

Next Steps:

For our internal staff, we advise identifying our clients’ jurisdictions and comparing them to the zip codes listed in the order, reviewing the business services that they provide and identifying if they have a cash stream of revenue. If there is any possibility that a client can be at risk to CRC, please reach out to me so we may take the next steps to mitigate our risk.

For our clients, please reach out to them and identify if they do business with any cash revenue firms in these areas as they may be a target of such illicit activities. Please send them the link below to the order for them to review the jurisdictions of their clientele.

As always, Compliance Risk Concepts is committed to fighting financial crime and has the expertise to assist financial institutions be compliance with the associated regulations and implement best practices for them and for the customers. For more information, please reach out to me at sfeldman@compliance-risk.com or visit our website at www.compliance-risk.com.

FinCEN Order Link:

https://www.fincen.gov/news/news-releases/fincen-issues-southwest-border-geographic-targeting-order

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