FinCEN Lowers Cash Reporting Threshold to Combat Cartel Money Laundering

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) launched a Geographic Targeting Order (GTO) requiring Money Services Businesses (MSBs) in specified U.S.-Mexico border ZIP codes to file Currency Transaction Reports (CTRs) for cash transactions exceeding $200, significantly lowering the previous threshold of $10,000. This measure aims to combat money laundering linked to Mexican drug cartels and is part of a broader governmental strategy under the Trump Administration to dismantle transnational criminal organizations. MSBs must enhance customer identification processes and provide detailed information for transactions, which could complicate financial activities for residents in the affected areas. The GTO is set to be enforced starting April 10, 2025, and will remain in effect for at least 180 days. The move has received mixed reactions, with some advocacy groups expressing concerns about the operational burdens placed on MSBs and potential negative impacts on local businesses. Overall, the GTO represents a significant shift in regulatory focus towards lower-value cash transactions, which authorities believe are commonly used by cartels to launder money.