Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-18.
“Specific counties and ZIP codes in Arizona, California, New Mexico, and Texas along the U.S.-Mexico border”
Threshold
$200
Effective
September 8, 2025
Expires
March 6, 2026
Geography
ZIP code
FinCEN expanded the Southwest Border MSB GTO in September 2025 to cover Arizona and New Mexico border counties in addition to the original California and Texas coverage. MSBs in covered areas must file CTRs for cash transactions of $200 or more. This order was superseded by the March 2026 expansion which raised the threshold to $1,000.
Formal Geographic Text (from order)
“Specific counties and ZIP codes in Arizona, California, New Mexico, and Texas along the U.S.-Mexico border”
Expanded from March 2025 order to include AZ (Maricopa, Pima, Santa Cruz, Yuma) and NM (Doña Ana). CA and TX coverage same as March 2025 order.
Who Must Report
Money services businesses (currency dealers/exchangers, check cashers, money transmitters) in covered counties/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
Expanded to AZ (Maricopa, Pima, Santa Cruz, Yuma) and NM (Doña Ana). CA and TX coverage unchanged.
Superseded by March 2026 order which raised threshold to $1,000 and added NM counties.
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
Second iteration of the 2025 Southwest Border MSB GTO. Added AZ and NM coverage. Superseded by gto-msb-sw-border-2026-01.
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.
