Money transmitters and currency exchanges along stretches of the Texas and New Mexico border are now operating under a federal order that requires far more cash transactions to be reported than federal law otherwise demands. The Financial Crimes Enforcement Network reissued its southwest border Geographic Targeting Order effective September 3, 2026, lowering the currency-transaction reporting threshold for those businesses from the standard $10,000 down to $1,000 inside a defined set of counties. For older Americans who use wire-transfer counters, check-cashing outlets or currency exchanges near the border to send remittances or convert cash, the order changes what gets recorded and reported to the federal government about routine transactions. Its geography has also shifted meaningfully since the version FinCEN circulated a year earlier, dropping some regions entirely while pulling in new ones.
Bernalillo County’s Zip Codes Enter the Order
Under the order FinCEN published in the Federal Register, money services businesses located in a broad set of zip codes across Bernalillo County, the county that contains Albuquerque, must now file a Currency Transaction Report on any cash transaction of $1,000 or more, up to $10,000, within 30 days of the transaction. That marks a sharp departure from the order FinCEN circulated in September 2025, which did not reach New Mexico at all.
The order FinCEN issued on September 10, 2025 covered money transmitters in Texas, Arizona and California border counties but did not reach New Mexico. Bernalillo, Dona Ana and San Juan counties entered the order’s coverage when FinCEN renewed it in March 2026, and all three remain covered under the version now in effect, published as 91 FR 56776, which runs through March 1, 2027.
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Arizona and California Drop Off the Map
The order FinCEN put in place in March 2026 covered Maricopa, Pima, Santa Cruz and Yuma counties in Arizona, along with select zip codes in Imperial and San Diego counties in California, in addition to the Texas and New Mexico territory. None of that Arizona or California ground appears in the order FinCEN signed on September 2, 2026. A currency exchange counter in Yuma or a check-cashing storefront in San Diego County is, under this reissued order, no longer subject to the $1,000 reporting threshold, though it remains bound by the standard federal rule requiring a report on any cash transaction above $10,000.
FinCEN’s notice gives no public explanation for narrowing the geography. The order states only that the agency’s Director found reasonable grounds to conclude the additional recordkeeping requirements remain necessary to carry out the purposes of the Bank Secrecy Act in the counties that stayed on the list.
Five Texas Counties Keep Their Reporting Rules
Cameron, El Paso, Hidalgo, Maverick and Webb counties in Texas have appeared in every version of the border order FinCEN has issued since 2025, and all five remain covered under the current one. Money services businesses in those counties’ zip codes must verify a customer’s identity under federal recordkeeping rules before completing a covered transaction and record the specific document used to do it, a driver’s license number or a credit card account number, for example, rather than noting “known customer” on the filing.
Each report filed under the order must carry the code “MSB0926GTO” in Field 45 of the Currency Transaction Report, distinguishing it from a routine CTR filed for a transaction over $10,000. The requirement to verify and record identifying information tracks the standard set out at 31 CFR 1010.312, which applies across the Bank Secrecy Act’s recordkeeping regime, not only to this order.
Money Transmitters, Not Banks, Carry the Paperwork
The order applies only to a “Covered Business,” defined as a money services business under 31 CFR 1010.100(ff), check cashers, currency dealers and exchangers, and money transmitters, among others, located in the covered zip codes. A transaction between one of those businesses and a commercial bank is explicitly exempted from the reporting requirement, and the order does not change how banks handle their own customers’ cash deposits or withdrawals.
That distinction matters for anyone reading headlines about a $1,000 reporting threshold along the border: the lower threshold, and the extended 30-day filing window in place of the standard 15 days, apply only to that narrower category of money services businesses inside the covered zip codes, not to a checking or savings account at a bank branch.
A 180-Day Clock That Resets Every March and September
Federal law caps a Geographic Targeting Order at 180 days unless the Treasury Department renews it, and FinCEN’s Director used the maximum period again this cycle: September 3, 2026 through March 1, 2027. Money services businesses that were not covered under the March 2026 version of the order have until October 3, 2026 to come into compliance in the newly listed zip codes.
Deputy Director Jimmy L. Kirby signed the current order on September 2, 2026, continuing a pattern FinCEN has followed since March 2025: renewing some version of the southwest border order roughly every six months, and redrawing which counties carry the $1,000 threshold each time it does.
This article was produced with the assistance of AI and reviewed by The Financial Wire editorial team.
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Warren Cohen is a finance writer based in Phoenix, Arizona, covering personal finance topics including credit, banking, and beginner investing. He earned his degree in business administration from Arizona State University and began his career working in consumer finance, where he gained direct experience with lending and credit systems. He now writes for personal finance websites and fintech platforms, focusing on clear, practical content that helps readers make informed financial decisions.
