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"On July 13, a divided Ninth Circuit panel upheld a lower court order that barred enforcement of FinCEN’s border Geographic Targeting Order (“GTO”). The GTO would have forced money services businesses (“MSBs”) in 30 ZIP codes along the U.S.-Mexico border to report cash transactions of just over $200, a dramatic reduction from the longstanding $10,000 reporting threshold. The decision in Novedades Y Servicios, Inc. v. FinCEN, 181 F.4th 961, 967 (9th Cir. 2026)  is a significant procedural check on the administration’s anti-cartel enforcement agenda."

"The Trump administration has repeatedly framed cartel-linked money laundering as a national security threat. On January 20, 2025 – the first day of his second term – President Trump issued an executive order designating certain international cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists. The order declared that cartels “present an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States,” and set its goal as “the total elimination of these organizations’ presence in the United States.”"

"The border GTO flowed directly from that priority. Issued by FinCEN in March 2025, the GTO targeted MSBs in 30 ZIP codes along the U.S.-Mexico border, requiring a Currency Transaction Report (“CTR”) filing for any cash transaction between $200 and $10,000. Treasury Secretary Scott Bessent made the administration’s priorities clear: “[f]or too long, cartels have abused the U.S. financial system to profit from poisoning Americans with deadly fentanyl. At Treasury, we are expanding our efforts to keep drug money out of the United States and to provide law enforcement with additional information to put these traffickers behind bars.”"

"The panel’s decision turned on administrative procedure rather than the merits of AML enforcement."

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