From April 14 to September 9, 2025, tax preparers and other Money Services Businesses (MSBs) in select California and Texas ZIP codes will face heightened reporting duties under a new Geographic Targeting Order (GTO) issued by FinCEN. If you’re in one of the affected regions, you need to understand how this order reshapes your compliance landscape.
Let’s break it down.
What Is a Geographic Targeting Order (GTO)?
A GTO is a temporary directive issued by the Financial Crimes Enforcement Network (FinCEN), part of the U.S. Treasury. Under the Bank Secrecy Act (BSA), a GTO requires businesses in a defined location to maintain additional records or report specific transactions—usually as part of efforts to combat money laundering or suspicious financial activity.
Typically, a GTO lasts up to 180 days but may be extended.
Affected Locations: Is Your ZIP Code on the List?
This latest GTO applies to specific ZIP codes along the Southwest U.S. border. Here are the regions under scrutiny:
California
- Imperial County: 92231, 92249, 92281, 92283
- San Diego County: 91910, 92101, 92113, 92117, 92126, 92154, 92173
Texas
- Cameron County: 78520, 78521
- El Paso County: 79901, 79902, 79903, 79905, 79907, 79935
- Hidalgo County: 78503, 78557, 78572, 78577, 78596
- Maverick County: 78852
- Webb County: 78040, 78041, 78043, 78045, 78046
Who’s Covered? Understanding Money Services Businesses (MSBs)
If you’re a tax preparer offering more than just returns—like cashing checks, transmitting money, or dealing in stored-value cards—you might be classified as an MSB.
MSB Categories Include:
- Currency dealers or exchangers
- Check cashers
- Issuers of traveler’s checks or money orders
- Sellers/redeemers of prepaid or stored value
- Money transmitters
- Certain roles by the U.S. Postal Service
Important: Simply collecting tax prep fees in cash doesn’t make you an MSB. But if you offer services like money transmission, you’re likely included.
Key Compliance Changes Under This GTO
1. Lower CTR Threshold
Normally, Currency Transaction Reports (CTRs) are required for cash transactions over $10,000. But under this GTO, any cash transaction over $200 and up to $10,000 must be reported.
This lowers the bar significantly and brings smaller cash-based interactions under scrutiny.
2. Applies to Physical Currency Only
The rule targets cash only—no checks, no cards, no digital payments. We’re talking cold, hard cash: deposits, withdrawals, exchanges.
3. Reporting Deadline & Filing Process
- File your CTR through the BSA E-Filing System
- Use the code “MSB0325GTO” in Field 45 (Part IV)
- Reports must be submitted within 15 days of the transaction
- Retain these records for five years after the GTO ends
What Transactions Are Covered?
Let’s say Terry, a tax preparer in El Paso (ZIP 79903), also cashes checks and offers money orders. If Terry accepts $500 in cash from a client to cash a check, he must file a CTR—even though the amount is well below the usual $10,000 threshold.
Reporting Triggers:
- Deposits/Withdrawals: Cash in or out of accounts
- Currency Exchanges: Swapping dollars for foreign currency or vice versa
- Transfers & Payments: Cash used to pay or receive funds
Note: You don’t need to aggregate separate transactions (like multiple $100 payments) unless otherwise required by standard BSA rules.
What Happens If You Ignore It?
Failing to comply with the GTO isn’t just a paperwork oops—it can trigger some serious consequences:
- Civil Penalties: Up to $286,184 per violation
- Criminal Charges: Possible in severe or willful cases
Don’t risk it—compliance is not optional.
Action Steps for MSBs & Tax Preparers
- Identify Covered Transactions: Review recent and upcoming cash transactions that may meet the new threshold.
- Update Systems: Make sure your software or manual process flags and logs transactions over $200.
- Train Your Team: Everyone involved in handling cash should understand the new rules.
- Consult a Pro: Unsure if you qualify as an MSB? This is the time to talk to a CPA (like us!) or a compliance expert.
Final Thought: Compliance Now, Peace of Mind Later
At JS Morlu, we know how fast regulatory landscapes shift. This GTO isn’t just a formality—it’s a glimpse into broader enforcement trends targeting financial transparency in cash-heavy zones.
Need help understanding if this order affects your business? Want us to review your compliance process or file CTRs on your behalf? We’ve got you covered.
Contact JS Morlu for a compliance consultation today.
Need more details? Visit the FinCEN website or refer to official documentation for full guidance on GTO compliance.
