March 12, 2025

If you operate a “money services business” in one of seven counties in southern California or southern Texas, FinCEN’s March 11, 2025, GTO will change your Currency Transaction Reports (CTRs) to a $200 threshold, down from $10,000.

This change – which does not affect your pawn business — will require immediate attention for re-coding of your software system and re-training of store personnel who handle currency transactions that are included in the scope of federal “money services businesses” requirements.

The following counties are affected

▪ in California: Imperial County and San Diego County.

▪ in Texas: Cameron County, El Paso County, Hidalgo County, Maverick County, and Webb County.

The change will go into effect 30 days after the GTO is published in the Federal Register, which has not occurred. Team GRC will monitor when this date is set. The GTO will remain in effect for 179 days after publication.

Pawnbrokers report cash transactions from pawn and sales transactions on Internal Revenue Service Form 8300’s. The thresholds for pawn cash transactions have not been changed –or not yet! Team GRC will monitor all changes in Form 8300 requirements. Yesterday’s GTO does not apply to your pawn businesses.

The press release for this GTO can be read here: https://fincen.gov/news/news-releases/fincen-issues-southwest-border-geographic-targeting-order.