New Financial Reporting Rule Tracks Cash Transactions Over $200

As money services businesses (MSBs) and financial professionals, we’ve seen our fair share of rule changes, but this one’s turning more than a few heads. Starting April 14, 2025, the U.S. Treasury is rolling out a new financial reporting rule that lowers the bar, way lower. If someone is in one of 30 ZIP codes along the California–Texas border and drops just $200 in cash, boom, you're filing a Currency Transaction Report (CTR) to FinCEN. That’s right, two Benjamins now land you in official reporting territory under the latest Geographic Targeting Order (GTO). For MSBs, it’s go-time: update your systems, train your team, and brace for a flood of filings on transactions that used to be business as usual. For financial professionals advising these businesses or their cash-heavy clients, now’s the time to revisit those compliance playbooks and clear up any confusion before it turns into a problem. This isn’t just about chasing bad actors anymore; it’s about redefining what counts as “reportable.” Ordinary cash use is under a brighter spotlight, and like it or not, we’re all part of the front line. So, sharpen your pencils, update your policies, and help your clients stay clean, clear, and confident.

Smaller Cash, Bigger Oversight

Previously, non-banking financial institutions, such as Western Union, check cashing places, or money order counters, were only required to report cash transactions over $10,000. That threshold has been in place since the 1970s and has never been adjusted for inflation. If it had, we’d be talking about $70K to $180K today. But now, the U.S. Treasury has dropped the new financial reporting threshold to just $200, a staggering 99.8% cut. Treasury Secretary Scott Bessent called it a response to “deep concern” over cartel money flows. But for everyday consumers, it means more reports, more friction, and more financial scrutiny—especially for low-income and unbanked households already walking a tightrope.

Zip It Good

If you’re in San Diego, Imperial, Cameron, El Paso, Hidalgo, Maverick, or Webb County, welcome to the pilot zone. This covers only 7 counties (conspicuously skipping Arizona and New Mexico), but it's got Western Union, check cashing spots, and money order counters scrambling to comply with new financial reporting rules under GTO. Skeptics, like the Cato Institute, see this as a canary in the regulatory coal mine. “More than one million Americans are about to face a new level of financial surveillance,” warned Cato’s Nicholas Anthony. That’s the rub. Today, it’s border towns. Tomorrow? Your neighborhood.

Real Talk

Let’s break it down. The GTO isn’t just about tracking dirty money, it’s dragging legit transactions into the spotlight. We’re talking about:

• The unbanked (5.6 million U.S. households)
• Single parents, minority families, and disabled individuals
• Folks using money orders to pay rent or sending cash back home

These communities already lean on MSBs due to mistrust or lack of access to banks. Now, even buying a money order to pay your electric bill could mean giving up your taxpayer ID, home address, and transaction details to FinCEN. Yikes.

Watch Out for Structuring

Here’s where things get spicy. Trying to dodge reporting by breaking up a larger cash amount into smaller $200 chunks? That’s called structuring, and yes, it’s a federal offense. It doesn’t just raise eyebrows—it triggers a Suspicious Activity Report (SAR), a confidential alert financial institutions file when they spot potentially shady behavior, even if the total stays well below the $10,000 threshold. On the flip side, if someone simply walks into an MSB and drops $200 or more in cash in one go, and it happens to be within one of the 30 designated ZIP codes, it now requires a Currency Transaction Report (CTR). Under this new GTO, MSBs are required to file CTRs for any qualifying transaction, and they must do so within 15 days of the transaction date.

Remember, CTRs aren’t discretionary, they’re automatic once the threshold is hit. They capture personal details like name, address, taxpayer ID, and full transaction data. SARs, on the other hand, are triggered when something just doesn’t sit right, even if the dollar amount is small. For financial professionals, this means your role goes beyond processing. You’re also an educator. It’s not about hiding cash flow—it’s about helping clients stay compliant, avoid unintentional red flags, and understand the rules before those rules become problems.

What Financial Professionals Need to Do

This rule isn’t just another reg buried in the footnotes. It’s a shift. And here’s how to keep your head in the game:

• Know the ZIP codes: Train your team to flag transactions from these areas.
• Update compliance procedures: Make sure CTR thresholds reflect the new $200 rule.
• Educate your clients: Especially those who rely on cash or MSBs. Break down what a CTR is and how to avoid triggering a SAR.
• Watch for expansion: This could be the first domino in a national rollout.

Your job now? Be the translator between complex federal policy and real-world financial behavior.

It’s About Everyone Else

Sure, the administration says this is about fighting crime. But even law-abiding citizens making small withdrawals could find themselves part of a growing data collection machine. It’s less “show me the money” and more “show me your ID for twenty bucks.” This isn’t just regulatory noise, it’s a cultural shift in how America thinks about money, privacy, and government oversight. Professionals, your clients are going to need help navigating the new normal. Because at the end of the day, the question isn’t just: “Why $200?” It’s: “Who’s really being watched, and what’s coming next?”