Important Notice: New FinCEN Reporting Requirements for Southwest Border MSBs

Effective April 14, 2025: FinCEN has issued a Geographic Targeting Order requiring money services businesses in specific southwest border zip codes to report currency transactions between $200-$10,000 and verify customer identities. If applicable, contact sales@alltrustnetworks.com or help@alltrustnetworks.com to convert to Smart Check. Learn More

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Navigating FinCEN’s GTO Compliance with SmartCheck’s New CTR Threshold Feature

FinCENs GTO Compliance

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Compliance is an ongoing procedure that is impacted by changing regulatory requirements for Money Services Businesses (MSBs). Among the most critical of these are the FinCEN filing requirements that govern how MSBs report suspicious or large cash transactions. A recent update to SmartCheck is making this much easier for businesses operating in FinCEN Geographic Targeting Order (GTO) zones.

SmartCheck now supports configurable Currency Transaction Report (CTR) thresholds, empowering MSBs to comply with region-specific rules—such as those introduced under FinCEN’s GTOs—quickly and efficiently.

What’s the FinCEN Requirement?

FinCEN’s GTOs currently require MSBs in certain specific high-risk ZIP codes—particularly along the U.S.–Mexico border—to report cash transactions as low as $200, down from the usual $10,000. This expanded requirement is part of FinCEN’s broader efforts to monitor money laundering risks and deter structuring, where individuals intentionally keep transactions just under the reportable amount to avoid detection.

These FinCEN reporting requirements place a unique operational burden on MSBs, who must file CTR reports for much smaller amounts and maintain stricter oversight of customer transactions.

SmartCheck: Built for FinCEN Filing Compliance

With the latest release of the product update, SmartCheck uses intelligent automation and geographic customization to make it simpler for MSBs to comply with FinCEN filing and reporting requirements.

Configurable CTR Thresholds

SmartCheck enables users to customize CTR reporting thresholds by location. For businesses operating in areas targeted by FinCEN GTOs, this means setting a $200 threshold in impacted ZIP codes—without affecting reporting rules at other locations.

Automated FinCEN Filing Alerts

SmartCheck automatically detects qualifying transactions and prompts appropriate action. This reduces the risk of human error and ensures that FinCEN filing requirements are consistently met.

Audit-Ready Recordkeeping

All CTR filings and related documentation are securely stored within SmartCheck, aligning with FinCEN requirements for long-term record retention and transparency during audits.

Geographic Intelligence

Assign reporting rules to specific ZIP codes based on FinCEN registration data and GTO zone requirements, ensuring accurate filing by location.

Why This Matters for MSBs

Failing to adhere to FinCEN requirements can lead to very serious repercussions —including heavy penalties, loss of licensure, or criminal charges in cases of willful non-compliance. SmartCheck’s new feature helps MSBs reduce risk by ensuring that:

  • Every applicable transaction is detected and reported
  • Reporting rules can be adapted to local GTO standards
  • FinCEN registration and filing obligations are streamlined across locations

Ideal For…

This feature is critical for:

  • MSBs operating near the U.S.–Mexico border
  • Check cashers and currency exchangers in GTO ZIP codes
  • Businesses looking to streamline FinCEN reporting requirements
  • Compliance officers needing audit-ready CTR documentation
  • New MSBs navigating FinCEN registration and onboarding

Final Thoughts

Regulatory complexity is increasing—but SmartCheck is here to simplify it. The new CTR threshold configuration feature is purpose-built to meet FinCEN filing and reporting requirements, particularly for businesses affected by Geographic Targeting Orders.

By helping MSBs automate reporting and tailor compliance by location, SmartCheck isn’t just a tool—it’s your frontline defense against risk.

Explore the release in detail: SmartCheck GTO Feature Update

About AllTrust Networks

AllTrust Networks is the nation’s leading innovator of software and services for check cashing and alternative financial services solutions. Thousands of retailers use AllTrust for risk management and check processing, benefiting from AllTrust’s extensive databases of consumers and check maker networks. AllTrust manages the country’s largest consumer biometric database, with over 10 million enrolled customers and has processed more than $60-billion in checks. Headquartered in Herndon, VA, AllTrust is committed to serving the alternative financial services community.

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