Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.
“Specific ZIP codes in Imperial County and San Diego County, California; and Cameron County, El Paso County, Hidalgo County, Maverick County, and Webb County, Texas”
Threshold
$200
Effective
April 10, 2025
Expires
September 9, 2025
Geography
ZIP code
FinCEN issued this Southwest Border GTO on March 11, 2025, requiring money services businesses (MSBs) in specific ZIP codes across California and Texas border counties to file Currency Transaction Reports (CTRs) for cash transactions of $200 or more. The order targeted cartel-linked bulk cash flows and was superseded by the expanded September 2025 and March 2026 orders.
Formal Geographic Text (from order)
“Specific ZIP codes in Imperial County and San Diego County, California; and Cameron County, El Paso County, Hidalgo County, Maverick County, and Webb County, Texas”
ZIP-code level coverage in 7 border counties across CA and TX. CA ZIP codes: 92231, 92249, 92281, 92283 (Imperial); 91910, 92101, 92113, 92117, 92126, 92154, 92173 (San Diego). TX ZIP codes: 78520-78521 (Cameron); 79901-79905, 79907, 79935 (El Paso); 78503, 78557, 78572, 78577, 78596 (Hidalgo); 78852 (Maverick); 78040-78041, 78043, 78045-78046 (Webb).
Who Must Report
Money services businesses (currency dealers/exchangers, check cashers, money transmitters) in covered ZIP codes
What Must Be Reported
File Currency Transaction Reports (CTRs) for cash transactions of $200 or more; verify customer identity; retain records for 5 years; file within 30 days of transaction
Threshold
$200
All-cash transactions at or above
Source Agency
FinCEN
FinCEN news release | Federal Register
Original Southwest Border MSB GTO issued. Covers 30 ZIP codes in CA and TX. $200 threshold.
Superseded by expanded September 2025 order adding AZ and NM coverage.
Renewal Chain
Common questions about this specific GTO, with answers grounded in the official order text.
These answers are for informational purposes only and are grounded in the official FinCEN order text. They do not constitute legal advice.
Analyst Notes
First modern Southwest Border MSB GTO under the Trump administration. Issued in response to Executive Order designating cartels as Foreign Terrorist Organizations. Superseded by gto-msb-sw-border-2025-02.
Geographic Targeting Order - Bexar County, Texas (Real Estate)
$500K threshold
Geographic Targeting Order - Bexar County, Texas (Real Estate) 2024
$300K threshold
Geographic Targeting Order - Harris County, Texas (Real Estate) 2024
$300K threshold
Geographic Targeting Order - Dallas County, Texas (Real Estate) 2024
$300K threshold
Soflo Consulting
We offer risk assessments, AML policy creation, and AML program reviews & gap analysis for businesses operating in FinCEN GTO-covered jurisdictions.
