FinCEN imposes Minnesota reporting order on cross-border transfers

The Financial Crimes Enforcement Network’s Minnesota Geographic Targeting Order took effect on 11 August 2026 and runs through 6 February 2027. It applies to covered banks and money transmitters with a branch, subsidiary or office in Hennepin or Ramsey county for specified cross-border funds transfers of at least $3,000.

The order supports Treasury work concerning international money laundering related to government-benefits fraud in Minnesota, according to the Federal Register notice. FinCEN issued it under the Bank Secrecy Act’s geographic-order authority. It does not replace other reporting, recordkeeping or anti-money-laundering obligations.

The order requires both an institutional and a transaction test.

A covered business is a bank or money transmitter with a branch, subsidiary or office in either named county. A covered transaction is a transfer subject to the order’s referenced recordkeeping rules where that business accepts the payment or transmittal instruction as the originator’s bank or the transmittor’s financial institution. The originator or transmittor must provide an address in a covered area, while the beneficiary, recipient or receiving financial institution must be outside the US.

The order excludes an originator or transmittor that is a publicly traded company or another financial institution already subject to a Bank Secrecy Act anti-money-laundering programme. It also lists additional bank exclusions by reference to 31 CFR 1010.230(e)(2)(i)-(xvi).

Covered businesses must report through FinCEN’s Financial Industry Portal using the Special Measures file type, code FIN-65547-X3M6T and the Minnesota Fraud GTO CSV template. A report is due by the end of the month after the month in which the transaction occurred. For an August covered transaction, the first possible filing deadline is 30 September 2026.

Required information differs for banks and money transmitters. It includes existing transfer-record fields and additional information about the business, originator or transmittor, beneficiary or recipient, accounts and government-payment sources. The order also includes fields concerning ownership interests and, for specified hawaladar ledger entries, the use of cash couriers. For certain fields, a business may rely on information supplied by the originator or transmittor unless it knows facts that would reasonably call the information’s reliability into question.

The order requires a covered business to supervise its officers, directors, employees and agents, transmit the order to each agent in the covered area and deliver it to its chief executive or equivalent manager. Reports and compliance records must remain accessible for five years from the order’s last effective day, including any renewal period. FinCEN says willful violations may expose the business and responsible personnel to civil or criminal penalties.

The order expires on 6 February 2027 unless FinCEN renews or changes it. The next fixed filing deadline is 30 September 2026 for any covered August transaction.