FinCEN's Geographic Targeting Order: A Guide for Financial Firms

FinCEN has issued a Geographic Targeting Order requiring certain money services businesses along the southwest border of the United States to report and retain records of currency transactions of more than $200 but not more than $10,000, and to verify the identity of the person presenting each transaction. Published as 90 FR 12106 and effective April 14, 2025, the order sits under 31 CFR Part 1010, the Bank Secrecy Act's core recordkeeping and reporting rules. For financial firms with border-area money services operations, this is not a future compliance date to plan around — the reporting and verification duties are already in force, and the operational question is whether a firm's monitoring and recordkeeping already reflect the lower threshold this order sets.

This guide explains, in plain English, what the order requires, which businesses it reaches, what a firm should do given that the effective date has already passed, and how a firm keeps a location-specific reporting threshold like this one from quietly drifting back to standard practice over time. It leads with the obligation and the date, not with any product. The goal is to give compliance and BSA/AML teams a clear, sourced picture they can act on without re-reading the full Federal Register entry themselves.

Key Takeaways

• FinCEN issued a Geographic Targeting Order, published at 90 FR 12106 and effective April 14, 2025, requiring certain money services businesses along the southwest border to report and retain records of currency transactions of more than $200 but not more than $10,000.

• The order also requires covered businesses to verify the identity of the person presenting each in-scope transaction, per 90 FR 12106.

• The order was published March 14, 2025, and sits under 31 CFR Part 1010, the Bank Secrecy Act's recordkeeping and reporting framework; no RIN is assigned to this action.

• The order's precise geographic boundaries along the southwest border are spelled out in the Federal Register notice itself; this brief does not restate them, so confirm any specific location against 90 FR 12106 directly.

• This post is informational only and is not legal or tax advice; consult a qualified attorney or compliance professional before acting on any specific situation.

What this rule actually does

Read the order narrowly: it does not create a new nationwide currency-reporting threshold, and it does not apply to money services businesses generally. 90 FR 12106 requires certain money services businesses located along the southwest border of the United States to report and retain records of currency transactions of more than $200 but not more than $10,000, and to verify the identity of the person presenting each transaction. FinCEN, part of the Treasury Department, issued the order as a Geographic Targeting Order — a Bank Secrecy Act tool used to impose narrower, location-specific requirements without a full notice-and-comment rulemaking.

The table below summarizes the order as published. It adds no date, figure, or requirement beyond what the rule itself states.

Unlike a special measure that takes legal force the day it is published, this order had roughly a month between its March 14, 2025 publication and its April 14, 2025 effective date, per 90 FR 12106. For any covered business, that window has already closed — the reporting and verification duties described above are in force now, not pending.

Because this is a targeting order rather than a generally applicable rule, its exact geographic boundaries — which counties, ZIP codes, or border segments are covered — are spelled out in the order itself. This brief does not restate those boundaries; confirm them directly against 90 FR 12106 before deciding whether a specific location falls inside or outside the order's reach.

Who is affected

The order reaches certain money services businesses — FinCEN's term for currency exchangers, check cashers, money transmitters, and similar businesses defined under 31 CFR Part 1010 — that operate within the specific southwest border area the order describes. Firms should not assume the order is limited to a single type of money services business or a single state; the Federal Register notice itself is the controlling description of who is covered. A firm's first task is to confirm, against 90 FR 12106, whether any of its locations, agents, or franchisees fall inside the order's geographic reach.

Money services businesses that operate entirely outside the described border area are not directly reached by this particular order, and firms that are not money services businesses at all are not reached either. That said, banks, credit unions, and other financial firms that maintain correspondent accounts, agent agreements, or franchise relationships with border-area money services businesses may still want to understand the requirement in 90 FR 12106, since a counterparty's compliance posture under a location-specific order like this one can affect due-diligence and monitoring decisions on both sides of the relationship.

What Financial Firms should do before the date

Because 90 FR 12106 has been in effect since April 14, 2025, "before the date" here means before the next in-scope transaction, not before some point on a future calendar. A financial firm with money services operations near the southwest border should work through a few concrete steps:

1. Confirm scope directly against the order. Check 90 FR 12106 to determine whether any location, agent, or franchisee falls inside the order's described geographic area, rather than assuming based on general proximity to the border.

2. Lower the reporting trigger for in-scope locations. A monitoring workflow built around the standard $10,000 threshold will not catch the more-than-$200-but-not-more-than-$10,000 band this order requires reporting on.

3. Build identity verification into the point of transaction, not just the back-office report. The order specifically requires verifying the identity of the person presenting the transaction, per 90 FR 12106.

4. Tie recordkeeping to 31 CFR Part 1010. Retention periods and record content should satisfy both this order and the general Bank Secrecy Act rules it sits under.

5. Re-check the source periodically. Geographic Targeting Orders are commonly reissued or amended, and the Federal Register is the only place to confirm whether this specific order, 90 FR 12106, is still active in its current form.

Throughout, the operative framing is that the rule requires in-scope money services businesses to report and retain records of these currency transactions and verify the identity of the person presenting them, per 90 FR 12106 — it does not instruct any individual firm on how to redesign its monitoring program, and it is not a substitute for the firm's own legal and compliance judgment about its specific locations and relationships.

Operationalizing border-area compliance at volume

The hard part of a location-specific reporting threshold like this one is rarely the first read of the order — it is making sure a lower reporting trigger, an identity-verification step, and matching recordkeeping stay consistently applied across every border-area location and every shift, without quietly drifting back to the standard $10,000 logic everywhere else. That is a monitoring-and-consistency problem, and it is where US Tech Automations fits. Configured against the Federal Register feed, the platform can watch for new documents tied to this order's citation, 90 FR 12106, and flag any renewal, amendment, or follow-on FinCEN action so a location-specific rule like this one does not quietly lapse from a firm's monitoring logic simply because nobody re-read the original notice. You can see how that kind of monitoring and escalation workflow is structured on the US Tech Automations agentic workflows page.

How this fits the broader regulatory window

This order does not exist in isolation. It is one of 259 U.S. federal rules in our point-in-time index of rules published July 1, 2024 – July 5, 2026 by 10 agencies governing our covered industries. A single Geographic Targeting Order like this one is straightforward to read on its own; the harder problem is that financial firms are tracking many FinCEN and Treasury actions at once, several with their own effective dates, their own covered-business definitions, and their own geographic footprints. A firm that only tracks the generally applicable Bank Secrecy Act regulations can miss a narrower, location-specific instrument like this one, even though the recordkeeping and reporting duties are just as real for the businesses it covers.

The takeaway for compliance leadership is straightforward: the reporting and verification duties in 90 FR 12106 took effect April 14, 2025, and they apply narrowly to certain money services businesses along the southwest border rather than to the industry nationwide. Building a durable way to watch the Federal Register for orders like this one — and to confirm whether a specific location falls inside their reach — is what a rule like this one is really asking of covered institutions. Firms evaluating how that kind of ongoing monitoring fits their own compliance stack can see how the US Tech Automations pricing page breaks down the platform.

Frequently asked questions

What does this FinCEN order actually require?

It requires certain money services businesses along the southwest border of the United States to report and retain records of currency transactions of more than $200 but not more than $10,000, and to verify the identity of the person presenting each transaction. The order is published at 90 FR 12106.

When did the reporting requirement take effect?

The order is effective April 14, 2025, about a month after its March 14, 2025 publication in the Federal Register at 90 FR 12106.

Which money services businesses need to comply with this order?

Those operating within the specific southwest border area the order describes. The Federal Register notice at 90 FR 12106 is the controlling description of the covered geography — firms should confirm their own locations against it rather than assume based on general proximity to the border.

What CFR part does this rule fall under?

The order sits within the Bank Secrecy Act recordkeeping and reporting regulations at 31 CFR Part 1010, the same part FinCEN uses for its broader recordkeeping and reporting authority. No RIN is assigned to this particular order.

Does the order require verifying identity, or just reporting the transaction?

Both. Covered businesses must verify the identity of the person presenting a transaction that falls within the order's reporting band, in addition to recording and reporting the transaction itself, per 90 FR 12106.

What should a firm do if it is unsure whether a location falls inside the order's geographic reach?

Confirm the question directly against the Federal Register notice at 90 FR 12106 or with qualified BSA/AML counsel, rather than assuming based on a location's general distance from the border. The order's own text is the controlling document for its geographic scope.

Related guidance

For related financial-services compliance coverage, see our notes on the imposition of special measures prohibiting certain transmittals, the anti-money laundering regulations for residential real estate, and the private fund advisers compliance requirements.

Disclaimer

This article is provided for informational purposes only and does not constitute legal or tax advice. Reading it does not create an attorney-client relationship. Regulatory requirements are fact-specific, and you should consult a qualified attorney or tax advisor before acting on any matter discussed here. Every date, citation, RIN, CFR reference, and figure in this post is copied verbatim from the Federal Register and eCFR as of the snapshot date. Nothing is estimated, modeled, or extrapolated. This is not legal or tax advice.

Last reviewed: July 5, 2026.

Source: U.S. Federal Register (90 FR 12106); current text via eCFR, 31 CFR Part 1010.