FinCEN, Cartels, and Geolocation

Who says that geolocation isn’t a critical factor for persons and non-person entities alike?

ComplyAdvantage alerted me to a Geographic Targeting Order from FinCEN.

“The GTO requires all money services businesses (MSBs) located in 30 ZIP codes across California and Texas near the southwest border to file Currency Transaction Reports (CTRs) with FinCEN at a $200 threshold, in connection with cash transactions.”

Of course, the targeted “cartels, drug traffickers, and other criminal actors along the Southwest border” can easily evade the reporting requirements by going a little north, east, or west. After all, there are more than 40,000 ZIP codes….

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