Residents in select ZIP codes across California and Texas will soon be subject to heightened federal financial surveillance under a new order issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). The move significantly lowers the threshold for reportable cash transactions from $10,000 to just $200 in 30 ZIP codes along the U.S.–Mexico border.
The directive, known as a Geographic Targeting Order (GTO), takes effect April 14, 2025, and will remain in place through September 9, 2025, unless renewed. It applies to money services businesses (MSBs) operating in specified areas within San Diego and Imperial Counties in California, and Cameron, El Paso, Hidalgo, Maverick, and Webb Counties in Texas. These businesses include check cashers, money transmitters, currency exchanges, and providers of money orders and prepaid access.
According to FinCEN, the new reporting requirement aims to “combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border.” Treasury Secretary Scott Bessent said the policy is part of a “whole-of-government approach” to counter narcotics trafficking and transnational criminal networks.
MSBs in the designated ZIP codes must file Currency Transaction Reports (CTRs) for all currency transactions exceeding $200 and up to $10,000, using the BSA E-Filing System.
The order does not alter existing obligations under the Bank Secrecy Act (BSA) for transactions over $10,000 or for suspicious activity reporting.
The GTO encourages voluntary Suspicious Activity Reports (SARs) for attempts to evade the $200 threshold.
Violations may result in civil penalties up to $286,184 per violation and criminal penalties of up to $250,000 in fines and five years imprisonment.
Critics have raised concerns that the order will disproportionately impact low-income and immigrant communities that rely on MSBs for essential financial services such as remittances, paycheck cashing, and currency exchange.
Although Treasury officials emphasize that the GTO targets cartel-linked financial activity, the operational impact will extend to millions of ordinary transactions. For instance, a customer exchanging $210 in pesos at a currency booth in San Diego, or cashing a $250 paycheck in Laredo, would now trigger a mandatory report to FinCEN.
Civil liberties advocates warn that expanding surveillance to this level threatens financial privacy. “This order undermines long-standing Fourth Amendment expectations by placing everyday financial behavior under federal scrutiny,” said one legal expert familiar with BSA compliance.
The controversy follows past public backlash to similar data surveillance efforts, including the Biden administration’s abandoned proposal to monitor bank accounts with over $600 in annual activity, and a Department of Homeland Security initiative that collected millions of financial records across border states.
The GTO follows Executive Order 14157, signed by President Donald Trump on January 20, 2025, which designated several major Mexican drug cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The ZIP codes included in the GTO were identified by FinCEN as high-risk areas for financial activity associated with these groups.
FinCEN’s March 11 announcement described the GTO as an effort to “better identify and counter” the flow of drug proceeds and criminal finance through MSBs operating in U.S. border communities.
Despite its national security rationale, the policy’s efficacy remains debated. In 2023, financial institutions filed over 27 million reports under the BSA, yet only 372 criminal investigations were initiated by the IRS based on those reports. Industry groups argue that expanding the program further will impose steep compliance costs on businesses without meaningful gains in crime reduction.
Unless renewed, the GTO will expire on September 9, 2025, but the Treasury has the authority to extend it for successive 180-day periods. In the meantime, businesses must comply or face steep penalties.
Congress has yet to act on broader legislation to clarify the scope of financial privacy under the Constitution. Until it does, Treasury’s expanded surveillance regime is set to proceed, reshaping the financial landscape for millions in America’s border communities.
Frequently asked questions regarding these GTOs are available here.
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