FinCEN's Latest GTO Will Rechannel Illicit Funds Through New ZIP Codes
Litigation attorney Peter Hardy was quoted in a MoneyLaundering.com article about the U.S. Department of the Treasury's Financial Crimes Enforcement Network's (FinCEN) new Geographic Targeting Order (GTO) to combat illicit activities and money laundering of Mexico-based cartels, drug traffickers and other criminal actors along the Southwest U.S. border. The GTO affects 30 ZIP codes in California and Texas, touching cities including El Paso, Laredo, San Ysidro and Otay Mesa. Under the order, money services businesses (MSBs) must report remittances to Mexico valued at $200 or more. Practitioners interviewed for the article expressed expectations that money launderers and money mules will likely employ a range of tactics to redirect these cash transactions and avoid unwanted attention from the government. Mr. Hardy, a former federal prosecutor in fraud and financial crime cases, commented on how FinCEN approaches GTOs.
"There's some reasoning with the areas FinCEN selects, whether it's SARs [suspicious activity reports], other, prior BSA [Bank Secrecy Act-mandated] filings or ongoing investigations," he explained.
Mr. Hardy also contributed to a Holland & Knight alert on this topic.
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