Money Services Transaction Reports Over $200

Money Services Businesses (MSBs) are businesses that are not banks, but that provide financial services like check cashing, money transfers, and money orders. 

The GTO requires MSBs in certain counties and zip codes near the Mexican border in Arizona, Texas, and California to report cash transactions of $1,000 or more to a federal agency called the Financial Crimes Enforcement Network (FinCEN). To report a transaction, the MSB will need to collect customer identifying information and then submit a form called a Currency Transaction Report. MSBs must also retain all reports filed under the GTO for five years and make those records available to FinCEN and law enforcement upon request.

Usually, these types of reports are only required for cash transactions over $10,000. Lowering that reporting threshold to $1,000 dramatically increases the amount of paperwork that MSBs are required to file. For some businesses, this could mean hours of new paperwork every day.

For regular people at the border, this is also a massive invasion of privacy. Ordinary transactions—like cashing checks or sending money to family—are being tracked and reported in unprecedented ways.  

The GTO applies to MSBs in certain specified counties and zip codes in Arizona, Texas, and California. However, some businesses are covered by preliminary injunctions and therefore do not need to comply—at least as long as those preliminary injunctions remain in effect. Here is a more detailed breakdown: 

Arizona 
-The GTO applies to MSBs operating in Santa Cruz County and Yuma County.  
-None of the preliminary injunctions currently in place applies to Arizona.  
–For now, all MSBs in Santa Cruz and Yuma Counties must comply with the renewed GTO. 

California  
-The GTO applies to MSBs operating in certain zip codes in San Diego County and Imperial County: 91910, 92101, 92113, 92117, 92126, 92154, and 92173 in San Diego County; and 92231, 92249, 92281, and 92283 in Imperial County. 
-A preliminary injunction entered in Novedades y Servicios, Inc. v. FinCEN (Case No. 25-CV-886 JLS), bars application of the GTO to all MSBs in the Southern District of California, which includes both San Diego and Imperial Counties.  
-The government has appealed the preliminary injunction to the Ninth Circuit.  
–So long as the preliminary injunction remains in effect, no MSBs in California are required to comply with the renewed GTO.  

Texas  
-The renewed GTO applies to MSBs operating in Cameron County, El Paso County, Hidalgo County, Maverick County, and Webb County.  
-Preliminary injunctions entered in TAMSB v. Bondi and Valuta Corp. v. FinCEN bar application of the renewed GTO to businesses that are specifically named as plaintiffs in those cases.  
-The government has appealed the TAMSB preliminary injunction to the Fifth Circuit.  
–For now, all MSBs in the listed counties are required to comply with the renewed MSB unless they are participating as a named plaintiff in one of the two cases where preliminary injunctive relief has been entered. If you are unsure if you are a named plaintiff, then you almost certainly are not.  

The initial GTO went into effect on April 14, 2025. MSBs that were already subject to the initial GTO have to continue complying without interruption unless they are covered by a preliminary injunction.

MSBs that are in areas that were not covered by the initial GTO, but that are covered by the new GTO, will have to start complying with the GTO on October 10, 2025. 

The initial GTO expired on September 9, 2025, but was renewed. The renewed GTO now expires on March 6, 2026. But it may be renewed again beyond that date. 

You can find a copy of the Southwest Border GTO here. It is also available on FinCEN’s website and in the Federal Register (a publication of the United States Government). FinCEN’s FAQs providing additional information is available here.  

FinCEN’s decision to renew the GTO means that all three lawsuits should continue to move forward. Currently, the preliminary injunction in Novedades is on appeal to the Ninth Circuit, and the preliminary injunction in TAMSB is on appeal to the Fifth Circuit. Those appeals should move forward. The third case, Valuta, should also continue to move forward in the district court.

While preliminary relief does not reach every business subject to the renewed GTO, final relief in all three cases should be broader. Under a statute called the Administrative Procedure Act, courts can “vacate” unlawful agency action—meaning that action ceases to exist for anyone, not just the named plaintiffs in the case. All three cases ask the courts to vacate the GTO.  

If you are an MSB affected by the new GTO, and if you are interested in helping fight this new order, submit your information here.  

Not really. Cartels can dodge this requirement by moving cash a few miles to unlisted counties or zip codes. This is a dragnet that misses all the big fish, but it will snag plenty of law-abiding people and businesses. 

The Institute for Justice is a nonprofit public interest law firm that sues the government to challenge unconstitutional government action. We are litigating the three cases challenging the GTO, and our ultimate goal is to secure relief so that no business must comply with the GTO’s unlawful and unconstitutional demands.

As a public interest law firm, we represent all our clients free of charge.