September 10, 2025

On September 8, 2025, FinCEN published an Update on the Geographic Targeting Order it first announced in March 2025.  That GTO was about to expire. That GTO requires covered businesses to file currency transaction reports (CTRs) with FinCEN of transactions in currency of $200 or more, and to verify the identity of persons presenting such transactions and keep records.  Some NPA members in the affected parts of the United States who also have MSB businesses were covered by the March 2025 GTO.

The new GTO sets a threshold of $1,000 as opposed to the prior $200 threshold. It also provides 30 days for filing CTRs, rather than the usual 15 days. These are big wins for MSBs in the targeted areas.

Pawnbrokers are not MSBs unless they offer services such as check cashing, sales of money orders and gift cards or other prepaid access, and money transfer services.  Also, the GTOs do not apply to payments for goods, as opposed to covered payment transactions.

The March 2025 GTO was about to expire when FinCEN extended and amended it this week.  FinCEN set a new expiration date for most MSBs of March 6, 2026, unless the GTO is extended or revised again.

For MSBs that were not covered by the prior version, the expanded GTO becomes effective on October 10, 2025.  This effective date applies to MSBs in Santa Cruz County and Yuma County in Arizona that the March 14, 2025, GTO did not cover.

MSBs in Imperial County and San Diego County California will not be required to comply while court orders enjoining the application of the March 14, 2025, GTO remain in effect.  If you operate an MSB in those California counties, please consult the lawyers who represented those MSBs in their successful challenges to the March 14, 2025, GTO about changing in your obligations to comply.

The new Southwestern Border GTO can be found here: SWB GTO Order. The March 14, 2025, Federal Register notice of the original SWB GTO can be found at 90 Fed. Reg. 12106, https://www.govinfo.gov/content/pkg/FR-2025-03-14/pdf/2025-04099.pdf.

This notice is not legal advice. Please consult your local lawyer about how it may affect your business. 

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