New FinCEN Rule: What It Means for Border Businesses Handling Cash

In February 2025, the Financial Crimes Enforcement Network (FinCEN), part of the U.S. Department of the Treasury, announced a new rule aimed at stopping illegal cash movement near the U.S.–Mexico border. This rule affects specific ZIP codes in California and Texas. If your business handles cash and is located in one of the 30 affected ZIP codes, new reporting requirements could soon apply to you. The specific, affected ZIP codes can be found here.

What the Rule Says

Normally, financial institutions must file a Currency Transaction Report (CTR) for any cash transaction over $10,000. But starting April 14th, 2025, FinCEN is temporarily lowering that threshold to $200 for covered businesses in the targeted ZIP codes.

This means if someone brings in $200 or more in cash – for example, to pay a bill or buy a money order – you must file a CTR. You must also file one if the total of their cash transactions in a single business day adds up to $200 or more, even if no individual transaction hits that amount.

This change will stay in effect 179 days after going into effect, but FinCEN may extend or expand it.

Why FinCEN and the Department of Treasury are Taking Action

FinCEN says the move is in response to concerns about illegal cash-based activity in certain border communities. Law enforcement believes some individuals may be using smaller transactions—below the usual $10,000 threshold—to move money tied to drug trafficking or smuggling.

By lowering the reporting limit to $200, FinCEN hopes to collect more data, identify patterns, and stop bad actors from flying under the radar.

What Is a CTR?

A Currency Transaction Report (CTR) is a form that financial institutions must file with the government when a customer makes a large cash transaction. It includes:

• The customer’s name, address, and ID type
• The customer’s social security number or tax identification number
• The customer’s occupation
• The customer’s date of birth
• The amount, type, and date of the transaction
• Your business’s information and who handled the transaction

CTRs are filed electronically through the BSA E-Filing System and must be submitted within 15 days of the transaction. These reports help FinCEN and law enforcement track large cash movements that might be connected to crime.

How to Prepare

While banks offer tools to handle inflation, they are not the only option. Many people choose cash for privacy, better control over spending, or personal beliefs. Alternative financial services respect this choice and work to provide fair, affordable, and easy-to-use financial options.

If your business is in one of the affected ZIP codes, here’s how you can get ready:

• Check Your ZIP Code: FinCEN’s official notice lists all 30 ZIP codes covered by this rule. Only businesses in these ZIPs are affected.
• Know What a CTR Requires: to complete a CTR, you’ll need to:
  • Collect valid ID from the customer
  • Record the exact cash amount and transaction type
  • Submit the report electronically within 15 days

Train Your Staff

Make sure employees can recognize when the $200 threshold is reached—either in a single transaction or across multiple smaller ones. They should also know how to ask for ID and follow your CTR procedures.

Review Your Systems

Update any point-of-sale or tracking tools to flag when a CTR is needed. You may need to manually track cash totals per customer each day.

Stay Compliant

CTR records must be stored for five years. Make sure your filing and storage processes meet that requirement.

Monitor for Updates

This is a temporary measure, but FinCEN may expand it. Businesses near the affected ZIP codes should stay alert in case the rule is widened.

Could This Expand?

Possibly. If FinCEN finds this approach helpful in uncovering illegal activity, it may extend the $200 CTR threshold to other areas in the future. For now, only certain locations in California and Texas are affected – but this could change quickly.

Get a Great Partner

At Fidelity Express, we are here to help our agents navigate all the rules, regulations, laws, and best practices for money service businesses throughout 21 states. Learn more today or give us a call at 888-808-1961.