FinCEN Renews Geographic Targeting Order for Minnesota Banks, Money Transmitters

FinCEN renewed a Geographic Targeting Order requiring banks and money transmitters in Hennepin and Ramsey Counties, Minnesota, to report specified international fund transfers of $3,000 or more.

In the order, FinCEN stated the action furthers the Treasury's efforts to combat international money laundering related to government-benefit fraud in Minnesota. The renewed order incorporates a February 2026 exemption for banks regarding specified originators but is otherwise unchanged from the January 2026 order (see prior coverage). FinCEN also issued Frequently Asked Questions to assist covered businesses in complying with the reporting requirements.

The order applies to a "Covered Transaction," defined as a fund transfer where the originator or transmittor provides an address in the covered counties, where it is not a publicly traded company on an SEC-regulated exchange or a financial institution subject to Bank Secrecy Act AML program requirements, and where the beneficiary, the recipient, or the financial institution used to receive the funds is outside the United States. Covered banks must report information such as the originator's and beneficiary's identifying details and whether the funds derive from a government contract or benefit program. Covered money transmitters face similar reporting obligations, including disclosure of the transmittal's funding source and, for ledger-entry transmittals that track credits and debits with hawaladars (money brokers) located internationally, whether the transmitter uses cash couriers to settle those debits.

Covered businesses are required to submit reports through FinCEN's Financial Industry Portal by the end of the month following the transaction, and are required to retain all records related to compliance for five years after the order's effective period ends. Covered businesses are responsible for supervising compliance by their officers, directors, employees, and agents, and are required to transmit the order to their agents in the covered area and to their CEO. Willful violations may result in civil or criminal penalties.

The order takes effect on August 11, 2026, and expires on February 6, 2027.