Americans who live and do business in those ZIP codes—estimated to be more than one million Americans—will be reported if they spend more $200 in cash on items like money orders and traveler’s checks.
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The Trump administration is seeking more information about your financial transactions—but only if you live or do business in one of 30 ZIP codes. Beginning in April, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) will require persons in those ZIP codes—estimated to be more than one million Americans—to be reported if they try to spend more than $200 in cash or cash equivalent on items like money orders and traveler’s checks. That’s a dramatic expansion of the standard $10,000 cash reporting requirement.
The new Geographic Targeting Order (GTO), which has, as its stated purpose, “to further combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States,” was quietly introduced this week. The GTO requires all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to file Currency Transaction Reports (CTRs) with FinCEN at a $200 threshold for cash transactions. The threshold for all other areas remains $10,000.
GTO Details
The GTO has, as its supposed purpose, “to further combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States.”
The Order applies to money services businesses (MSBs) in ZIP codes across seven counties in California and Texas:
- Imperial County, California: 92231, 92249, 92281, 92283
- San Diego County, California: 91910, 92101, 92113, 92117, 92126, 92154, 92173
- Cameron County, Texas: 78520, 78521
- El Paso County, Texas: 79901, 79902, 79903, 79905, 79907, 79935
- Hidalgo County, Texas: 78503, 78557, 78572, 78577, 78596
- Maverick County, Texas: 78852
- Webb County, Texas: 78040, 78041, 78043, 78045, 78046
An MSB includes businesses like check cashing services, sellers of traveler’s checks or money orders, and money transmitters.
The effective date of the GTO is April 14, 2025.
Reporting Rules
Under current rules, financial institutions, including banks, must file Currency Transaction Reports (CTRs) when they accept $10,000 or more in cash in a single day. The term “cash” typically means money. Money can mean currency and coins of the United States and any other country. Cash can also include certain monetary instruments like a cashier’s check, bank draft, traveler’s check, or money order.
A CTR includes details about the person involved in the transaction, including their name, address, and taxpayer identification number. A CTR also contains information about the date, amount, and kind of the transaction.
After the CTR has been submitted, FinCEN collects and maintains the information, and authorized law enforcement and other agencies can use it to investigate and prosecute illicit finance activities.
It is not illegal to deal in cash—even if those dollars are significant. The idea of reporting large transactions that enter the country (via a FinCEN 105), are deposited or exchanged at banks or other financial institutions (via FinCEN 104), or are received in the course of a trade or business (via Form 8300) is to ensure that those dollars are properly reported and taxed. Money that is “dirty,” meaning that it was from illegal sources, is more difficult to circulate and exchange for “clean” money if reported. Similarly, it’s easier to ensure that funds are reported to the taxation authorities, if appropriate, when taxpayers are aware that the feds know that those funds exist.
The $10,000 threshold, established in 1972, has never been adjusted for inflation; if the threshold had been adjusted for inflation, it would be nearly $80,000. According to the Government Accountability Office (GAO), financial institutions filed roughly 167 million CTRs in fiscal years 2014–2023; adjusting for inflation would have reduced the number of CTRs filed by at least 90% annually since 2014.
That $10,000 threshold isn’t an absolute bottom limit. If a financial institution or MSB has reason to believe that a transaction was out of the ordinary, even if it’s for a much smaller amount of money, they must file a suspicious activity report (SAR). That includes structuring—when you break down really large transactions into smaller ones. For example, if you had $100,000 in “bad” funds that you wanted to get rid of, rather than putting it all in at once, you might break it down into 11 deposits of $9,091 to avoid being reported. Doing that with an intent to evade reporting is illegal.
Unbanked Persons
While the goal of the GTO is allegedly to target cartels (who knew that drug cartels relied on Western Union?), the new rule has the potential to ensnare those who rely on MSBs more heavily than traditional financial institutions, including the unbanked. According to the Federal Deposit Insurance Corporation (FDIC), a household is considered unbanked if no one in the household has a checking or savings account at a bank or credit union. In 2023, 4.2 percent of U.S. households—about 5.6 million households— were unbanked.
Unbanked rates are higher for certain populations, including lower-income and single-parent households. Rates are also higher for minority populations, including Black, Hispanic, and American Indian or Alaska Native households, and working-age households with a disability. For working-age households with a disability, the unbanked rate in 2023 was 11.2%—that’s three times higher than the unbanked rate among working-age households without a disability. For single-parent households, the unbanked rate was 12.3%—more than five times higher than the unbanked rate among married-couple households with one or more children.
When those who are unbanked were asked why, “Don’t have enough money to meet minimum balance requirements” was the most cited reason. (“Don’t trust banks” was second.)
Controversy
In response to the GTO, the libertarian think tank Cato Institute declared “this move is in the wrong direction.”
Financial surveillance has been a controversial subject for Americans. Taxpayers balked when the Biden administration moved to reduce reporting thresholds for third-party settlements—also on the grounds of reducing illegal activity. The increased oversight and record production involving those transactions worried privacy advocates and tax professionals.
In 2023, the IRS estimated there could be up to 44 million Forms 1099-K sent to taxpayers (the official IRS projections—released in September 2024—suggested that the numbers were much smaller because of the delayed implementation of the $600 reporting threshold).
A new rule requires reporting when certain financial transactions hit $600. Before the change, Form 1099-K required reporting when payments totaled more than $20,000 and more than 200 transactions were settled through a third-party network (one that is settled through a third-party payment network, such as PayPal—think payment app or online marketplaces). No threshold applies to payment card transactions—payment cards include credit, debit, or stored value cards such as gift cards.
After public outcry, the IRS announced that it would treat 2024 as an additional transition year (the IRS did the same for 2023). As a result, reporting will only be required if the taxpayer receives more than $5,000, regardless of the number of transactions in 2024. The dollar value will scale to $2,500 for transactions in 2025 before hitting the $600 threshold in 2026 and after.
What Does It Mean?
So far, no one has sounded the alarm on the GTO. That may be because not many people are talking about it. Those that are, including the Cato Institute, worry about the erosion of privacy guardrails. There is also a concern that this is just a first step—and expanded reporting requirements could be in the cards for any organization, ZIP code, or geographic area.
When asked specific questions about the Order, including how the ZIP codes and limit were selected and whether the reporting requirements might simply drive more financial transactions underground, FinCEN declined further comment beyond pointing to the press release and Order.
You can read the Order here.
