Sean Topchi
Since the start of the Trump administration, there has been much discussion about deregulation and lax enforcement due to the administration’s business friendly posture. However, the administration has taken a hard line on cartels, Latin American gangs, drugs and money laundering. That is translating to unprecedented scrutiny and challenges for AML regimes, including the recent Geographic Targeting Order (GTO).
The Geographic Targeting Order: An Overview
On March 11, 2025, FinCEN issued a GTO aimed at combating illicit activities and money laundering by Mexico-based cartels and other criminal actors along the southwest border of the United States
This order 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 zip codes covered under the order are as follows.
- Imperial County, California: 92231, 92249, 92281, and 92283;
- San Diego County, California: 91910, 92101, 92113, 92117, 92126, 92154, and 92173;
- Cameron County, Texas: 78520 and 78521;
- El Paso County, Texas: 79901, 79902, 79903, 79905, 79907, and 79935;
- Hidalgo County, Texas: 78503, 78557, 78572, 78577, and 78596;
- Maverick County, Texas: 78852; and
- Webb County, Texas: 78040, 78041, 78043, 78045, and 78046.
While CTRs are generally for an aggregation of transactions resulting in over $10,000, this order specifies that a CTR must be filed for each “covered transaction”. The orders definition for covered transactions is:
“Each deposit, withdrawal exchange of currency or other payment or transfer, by, through, or to the Covered Business which involves a transaction in currency of more than $200 but not more than $10,000.”
With a 98% decrease in reporting threshold, the resulting filing burden is several orders of magnitude beyond what MSBs would currently have to do and can result in thousands of extra filings per institution. The current order is in place for 179 days (6 months). The normal CTR requirement is also still in place during this period. Penalties for non-compliance have the same parameters as other parts of the regulation. All officers, directors, employees and agents may be liable to both civil and criminal penalties for violating the order.
Impacts of a Similar GTO on Casinos
Should this order be expanded to casinos and card clubs, at least 17 institutions would be required to file CTRs under this $200 threshold. Below are some of the challenges an order like this could pose to casinos.
- Technological Reporting Limitations: Many legacy AML software only create CTRs at the $10,000.01 threshold. If that is the case, the CTRs would either have to manually be created within the software and e-filed, or users would have to revert back to e-filing thousands of reports directly through the BSA website.
- Unknown Patron Transactions: Most patrons at the traditional CTR threshold are known or quickly become known. However, it is not uncommon for a substantial portion of a casino’s patron database to be unknown. As transactions get smaller, the amount of unknown patrons drastically increases. Casino operations and AML teams would have to work very closely together to identify every player buying in or redeeming $200 or more. The sheer impact on both operations and compliance would be almost incalculable.
- CIP Information Gathering: The GTO requires that same Customer Identification Procedures are followed for these $200 CTRs, as if they were regular CTRs. Casinos would be recording ID information on nearly every single transaction in the casino.
- Staggering CTR Volume: The overwhelming majority of transactions for casinos fall between the $200 and $10,000 described in the order. Casinos would be dealing with thousands of CTR filings, possibly per day. Compliance teams would have to multiply in size or acquire technological tools that could allow them to quickly identify and file these transactions in bulk.
- GTO Renewals – While the current order sits at 179 days, FinCEN tends to renew GTOs. The Real Estate GTO was continually renewed by FinCEN from the 2010s well into the 2020s year after year. A temporary GTO can become quasi permanent, meaning the surge in reporting is something institutions may have to plan for in the long term. Las Vegas strip casinos may remember getting orders targeted around high activity sports betting periods (i.e. March Madness) for heightened CTR reporting scrutiny, well before legalization happened across the country.
The Broader Context of AML/CFT Efforts
The issuance of this GTO is part of a broader strategy by the Trump administration to enhance the effectiveness of AML/CFT regulations and enforcement. In January 2025, President Donald J. Trump issued an Executive Order creating a process by which certain cartels and other organizations would be designated as Foreign Terrorist Organizations (FTOs) and/or Specially Designated Global Terrorists (SDGTs) (see our previous blog). This designation allows the United States to take further steps to deny individuals and entities associated with these groups access to the U.S. financial system.
With how fast this administration moves, all types of financial institutions and casinos need to buckle up and be prepared for what may be the first of many changes that create incredibly difficult operational challenges. Casinos partners and technology vendors need to be in close coordination to tackle the administration’s priorities as they impact our industry.