Southwest Border: Track Cash Deals Over Just $200 Now
Published Date: 3/14/2025
Rule
Summary
Starting April 14, 2025, certain money services businesses along the U.S. southwest border must keep records and report cash transactions between $200 and $10,000. They also have to check who’s making these transactions to help stop illegal money moves. This new rule aims to boost transparency and fight financial crimes in that area.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
Civil and criminal penalties for noncompliance
The Covered Business and its officers, directors, employees, and agents may be liable, without limitation, for civil or criminal penalties for violating any term of the Order.
Mandatory reporting of $200–$10,000 cash transactions
Covered MSBs must report each currency transaction of more than $200 but not more than $10,000 (a "Covered Transaction") to FinCEN on a Currency Transaction Report within 15 days after the transaction and must e-file the report through the BSA E-Filing System. Transactions with a commercial bank are excluded, and U.S. Postal Service outlets need not report payments made only for postage or philatelic products.
Which businesses and areas are covered
The Order applies to money services businesses (MSBs) located in specified ZIP codes across seven counties on the U.S. southwest border (listed for Imperial and San Diego Counties in CA, and Cameron, El Paso, Hidalgo, Maverick, and Webb Counties in TX). The Order is effective April 14, 2025 through September 9, 2025.
Identity verification and specific ID data required
Before completing a Covered Transaction, the Covered Business must verify the customer's identity under 31 CFR 1010.312 and record the specific identifying information (for example, a driver's license number or credit card account number) on the Currency Transaction Report. The report cannot simply note "known customer" or "bank signature card on file."
Five-year records retention and access requirement
Covered Businesses must keep all reports filed under the Order and any related compliance records for five years from the last day the Order is effective (including renewals), store them so they are accessible within a reasonable time, and make them available to FinCEN or other law enforcement or regulatory agencies upon request.
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Key Dates
Department and Agencies
Related Federal Register Documents
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2026-20429, Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal
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2026-18194, Geographic Targeting Order Imposing Recordkeeping and Reporting Requirements on Certain Money Services Businesses Along the Southwest Border
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