What is a Geographic Targeting Order (GTO)?

What is a Geographic Targeting Order (GTO)?

A Geographic Targeting Order (GTO) is an order issued by the United States Secretary of Treasury requiring any United States domestic financial institutions that exist within a geographic area to report on transactions any greater than a specified value. 

Financial Crimes Enforcement Network (FinCEN) is authorized to issue an order that imposes certain additional reporting and recordkeeping requirements on one or more domestic financial institutions or nonfinancial trades or businesses in a geographic area to carry out the purposes of and prevent evasions of the Bank Secrecy Act. 

The businesses covered in the Los Angeles GTO include the following trades and businesses located in the Covered Geographic Area, including their agents, subsidiaries, and franchisees: 


(a) garment and textile stores; 
(b) transportation companies; 
(c) travel agencies; 
(d) perfume stores; 
(e) electronic stores (including those that only sell cell phones); 
(f) shoe stores; 
(g) lingerie stores; 
(h) flower/silk flower stores; 
(i) beauty supply stores; 
(j) stores bearing “Import” or “Export” in its name 

Special Reporting, Recordkeeping, and Customer Identification Obligations of the Covered Businesses. 

A Covered Business which, in the course of a trade or business in which such business is engaged, receives currency in excess of $3,000 in 1 Transaction (or 2 or more related Transactions in a 24 - hour period) shall make a report of each such Transaction or Transactions by filing a FinCEN Form 8300. Each such FinCEN Form 8300 must be: 

(a) completed in accordance with the terms of this Order and the FinCEN Form 8300 instructions (when such terms conflict, the terms of this Order shall apply); and 
(b) filed through the Bank Secrecy Act E-filing system. 

4/21/2015 - A GTO was issued for 700 electronic exporters in Miami, bringing their transactions under stricter scrutiny while law enforcement look for evidence of trade-based money laundering schemes often used by violent criminal organizations to launder their profits. The GTO is in effect for 180 days. 

According to HSI and FinCEN, many electronics exporters are exploited by South American drug cartels as part of sophisticated trade-based money laundering schemes. The cartels allegedly convert cash from United States drug sales into electronics goods, which are shipped to South America and sold for local currency. That currency is ultimately transferred to the drug cartels in their home countries. 

The original Geographic Targeting Order was issued in 1998 in coordination with the US Customs Service Task Force called Operation El Dorado. The GTO targeted money service businesses (MSBs) in the Jackson Heights sections of New York City

FinCEN 21/4/2015 issuing:

CONTACT: Steve Hudak 703-905-3770

For Immediate Release April 21, 2015

FinCEN Targets Money Laundering Infrastructure with Geographic Targeting Order in Miami

WASHINGTON, DC – The Financial Crimes Enforcement Network (FinCEN) issued aGeographic Targeting Order (GTO) today to about 700 Miami businesses to shed light on cash transactions that may be tied to trade-based money laundering schemes. These complex schemes are a primary method used by drug cartels, including the Sinaloa and Los Zetas, to launder their illicit proceeds. FinCEN's order is aimed at disrupting the illicit financial infrastructure upon which these drug trafficking organizations rely.

FinCEN, in coordination with U.S. Immigration and Customs Enforcement's Homeland Security Investigations (HSI) and Miami Dade State Attorney's Office South Florida Money Laundering Strike Force, issued the GTO on electronics exporters located near Miami, Florida. Law enforcement investigations reveal that many of these businesses are exploited as part of sophisticated trade–based money laundering schemes in which drug proceeds in the United States are converted into goods that are shipped to South America and sold for local currency, which is ultimately transferred to drug cartels. This GTO enhances the transparency of the covered businesses' transactions; it does not make any determination about their knowledge or lack thereof of the money laundering schemes.

In general, a nonfinancial trade or business that receives more than $10,000 in currency in a single transaction or multiple related transactions is required to file a Form 8300 with FinCEN. The GTO, which will be in effect for 180 days beginning on April 28, 2015, lowers the $10,000 reporting threshold to $3,000 for covered businesses. These businesses are required to report to FinCEN currency transactions over $3,000, and to include in those reports information about the transaction and the persons involved. Each business covered under this GTO has received notice of its obligations via personal service or by certified mail. Failure to comply could result in substantial criminal and civil penalties. The enhanced financial transparency provided by the GTO will bolster law enforcement’s ability to identify and prosecute the money launderers who service drug trafficking organizations and other criminal networks.

“When we issued a similar GTO in the Los Angeles area last year, many speculated about whether we’d be doing the same in other parts of the country,” said FinCEN Director Jennifer Shasky Calvery. “We are committed to shedding light on shady financial activity wherever we find it. We will continue issuing GTOs, as necessary, as well as exercising FinCEN's other unique anti-money laundering authorities, to ensure a transparent financial system that impedes money launderers and other criminals from masking their identity and illicit activity.”

Executive Associate Director for Homeland Security Investigations, Peter Edge noted, “A GTO is one of many tools available in the fight against money laundering. Past successes show that GTOs can be effective in exposing criminal organizations using legitimate financial institutions and businesses to facilitate their illicit dealings. Homeland Security Investigations is dedicated to disrupting these activities and dismantling these organizations to protect the security of the nation's financial infrastructure.”

Businesses covered by the GTO have been served a copy of the order and must begin complying on April 28, 2015. A copy of the order may be found here. Any questions about the order should be directed to the FinCEN Resource Center at 800–767–2825.

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