FinCEN issues Minnesota GTO requiring banks and transmitters to report $3,000 transfers
Banks and money transmitters with branches in Hennepin or Ramsey County must file detailed CSV reports of qualifying transfers through FinCEN's FI Portal beginning Aug. 11, 2026.
FinCEN issued a Geographic Targeting Order (GTO) that becomes effective on August 11, 2026. The order applies to any bank or money transmitter that maintains a branch, subsidiary, or office in Hennepin County or Ramsey County, Minnesota. Covered transactions are funds transfers of $3,000 or more that meet the criteria set out in the order, including transfers where the originator's address is in the covered area and the beneficiary or recipient is located outside the United States.
The order requires each Covered Business to submit a CSV file through FinCEN's Financial Industry (FI) Portal. Submissions must be filed under the file type "Special Measures" using the identifier "FIN-65547-X3M6T." The required template is the Minnesota Fraud GTO Submission Template, and file names must follow the format FilerName_TransactionYearMonth_File#ofTotal#_MNGTO2026.csv. Reports are due by the end of the month following the month in which the Covered Transaction occurs.
Banks must report all information required under 31 CFR 1020.410(a)(1) and (2) plus the name and EIN of the bank, originator's account number, beneficiary's name, address, date of birth, phone, email, account number, and whether the source of funds includes any government contract or benefit payments and any ownership interest the originator may have. Money transmitters must report all information required under 31 CFR 1010.410(e)(1) and (2) plus the transmitter's name and EIN, recipient's name, address, date of birth, phone, email, source of funds, form of transmittal, and, where applicable, details about cash couriers and hawaladars.
The GTO remains in effect until February 6, 2027. Covered Businesses must retain all reports and related records for five years after the order's effective date and make them available to FinCEN or other law-enforcement agencies upon request. Non-compliance may result in civil or criminal penalties. The order does not modify any other BSA provisions and is not confidential.