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Background
On March 14, 2025, FinCEN issued the March GTO, requiring MSBs located in 30 zip codes in California and Texas to file Currency Transaction Reports (CTRs) with FinCEN for currency transactions exceeding $200 (up to $10,000) within 15 days of the date when the transaction occurred, and verify the identity of persons making such transactions. The March GTO expired on Sept. 9, 2025.
On Sept. 8, 2025, FinCEN issued the September GTO, expanding the scope of the March GTO to include Santa Cruz County and Yuma County in Arizona, and requiring affected MSBs to: (i) file CTRs with FinCEN for transactions involving between $1,000 and $10,000 in currency within 30 days of the date when the transaction occurs; and (ii) verify the identity of persons making such transactions. The September GTO is effective until March 6, 2026, unless renewed.
Which MSBs Does the September GTO Cover?
Except for MSBs as to which FinCEN is legally enjoined from enforcing the March GTO, MSBs1 that were covered by the March GTO are subject to, and must comply with, the September GTO.2
MSBs newly subject to the September GTO are those located in the recently added counties of Santa Cruz and Yuma, Arizona.
MSBs covered by the September GTO are expected to supervise and are responsible for compliance by each of their officers, directors, employees and agents. Covered MSBs must also transmit the September GTO to each of their agents located in the affected areas.
What Transactions Does the September GTO Cover?
The September GTO requires covered MSBs to report each deposit, withdrawal, exchange of currency, or other payment or transfer – made by, through, or to the covered MSB – involving between $1,000 and $10,000 in currency.
The transaction must be reported to FinCEN within 30 days of the date when the transaction occurred (up from the 15 days provided under the March GTO), and by filing a CTR with FinCEN through FinCEN’s Bank Secrecy Act (BSA) E-Filing System.
The record retention requirements remain unchanged from the March GTO.3
Key Takeaways for Covered MSBs
The September GTO revises the March GTO’s requirements by (i) expanding its scope to include two counties in Arizona; (ii) increasing the reporting threshold from $200 to $1,000; (iii) extending the CTR submission deadline from 15 days to 30 days following the transaction; and (iv) exempting entities covered by the two existing injunctions, unless and until those injunctions are lifted.
MSBs subject to the March GTO should review and consider updating their controls to account for the higher threshold and the extended 30-day submission deadline, and ensure they have adequate controls in place for any operations located in the newly covered jurisdictions.
Newly covered MSBs (i.e., MSBs located in Santa Cruz and Yuma Counties, Arizona) may wish to review the September GTO’s requirements and implement adequate controls to be prepared to comply by Oct. 10, 2025. Compliance efforts may include updating existing risk assessments, reviewing BSA-mandated compliance programs, and training customer-facing and compliance staff.
MSBs subject to the injunctions in Texas and California should continue to monitor updates to their respective injunctions. While these injunctions currently exempt such MSBs from FinCEN’s GTO requirements, the exemption will cease if the applicable injunction is lifted.
Covered MSBs should closely monitor regulatory updates from FinCEN, as GTOs are commonly renewed and, at times, expanded to address emerging areas of concern.
1 FinCEN regulations define an “MSB” to include dealers in foreign exchange, check cashers, issuers or sellers of traveler’s checks or money orders, providers of prepaid access, money transmitters and sellers of prepaid access. 31 C.F.R. § 1010.100(ff).
2 FinCEN is currently enjoined from applying the March GTO to (i) members of the Texas Association of Money Services Businesses in Texas; and (ii) MSBs operating in Imperial County and San Diego County, California. Texas Ass'n of Money Services Businesses v. Bondi, 783 F. Supp. 3d 963 (W.D. Tex. 2025), and Novedades y Servicios, Inc. v. Fin. Crimes Enf't Network, 785 F. Supp. 3d 785 (S.D. Cal. 2025). Until and unless these injunctions are lifted, MSBs subject to these injunctions are exempt from the definition of Covered MSB for purposes of complying with the September GTO.
3 See our March 2025 GT Alert for more details.