Taking $200 Out of an ATM Should Not Trigger Federal Financial Surveillance
One of President Donald Trump’s Day 1 executive orders designated “certain international cartels” as “foreign terrorist organizations,” a classification that according to the State Department “play[s] a critical role in our fight against terrorism and [is] an effective means of curtailing support for terrorist activities and pressuring groups to get out of the terrorism business.”
To that end, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a new rule cracking down on cash transactions this week, but only in certain geographical regions. No matter the administration’s intent to target cartels, the rule will expand government surveillance of its citizens.
FinCEN “issued a Geographic Targeting Order (GTO) 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,” according to the announcement. “The GTO requires all money services businesses (MSBs) located in 30 ZIP codes across California and Texas near the southwest border to file Currency Transaction Reports (CTRs) with FinCEN at a $200 threshold, in connection with cash transactions.”
Treasury Secretary Scott Bessent said the change “underscores our deep concern with the significant risk to the U.S. financial system of the cartels, drug traffickers, and other criminal actors along the Southwest border.”
The order lists all 30 ZIP codes in counties that each abut the U.S.–Mexico border: San Diego and Imperial Counties in California; and Cameron, El Paso, Hidalgo, Maverick, and Webb Counties in Texas. California’s are the state’s only two border counties, but the five in Texas encompass only a small portion of the state’s total southern border. It’s not clear why these seven counties were chosen out of the 44 total border counties, including any in Arizona or New Mexico.
Federal law requires banks, as well as businesses that provide services like check cashing or currency exchange, to fill out CTRs as a means of protecting against illegal activity like money laundering. Financial transactions totaling at least $10,000 in cash per day—in
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