“Geographic Targeting Order” and Guidance Issued to Guard Against Misuse of Armored Cars
WASHINGTON, D.C. – The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in close coordination with its Mexican counterpart, the Unidad de Inteligencia Financiera (UIF), today announced a series of reporting initiatives designed to greatly improve the transparency of cross-border cash movements. To address U.S. and Mexican law enforcement’s concerns about potential misuse of exemptions and incomplete or inaccurate reports filed by armored car services (ACS) and other common carriers of currency, FinCEN has issued a Geographic Targeting Order (GTO) that requires enhanced cash reporting by these businesses at the San Ysidro and Otay Mesa Ports of Entry in California. FinCEN also issued updated guidance concerning detailed and proper filing of Currency and Monetary Instruments Reports (CMIRs), which are filed when $10,000 or more in currency is moved across the U.S. border.
“Drug trafficking organizations and other criminal enterprises thrive when their cash movements are hidden from view,” said FinCEN Director Jennifer Shasky Calvery. “FinCEN is committed to working closely with our Mexican counterparts, law enforcement, and industry partners to bring greater transparency along our border and safeguarding the integrity of our financial systems.”
“The actions taken by FinCEN address an important issue that was identified jointly by U.S. and Mexican authorities and has our support,” said UIF Director Alberto Bazbaz Sacal. “Mexico and the United States will continue to further improve our fight against money laundering with this and other measures.”
“As part of HSI’s broader strategy to dismantle transnational criminal organizations and seize their illicit proceeds, we are actively targeting and identifying organizations that work to move money across the southwest border ports of entry,” said HSI Executive Associate Director Peter Edge. “We believe the Geographic Targeting Order is an invaluable tool toward achieving these goals. As such, we will continue to work with our partners in law enforcement and private industry to identify and shut down vulnerabilities susceptible to exploitation.”
In 2010, Mexico enacted new anti-money laundering (AML) provisions to attack the flow of illicit cash from the United States to Mexico. These efforts made it much more difficult for criminals and narco-traffickers to place large amounts of cash in Mexican financial institutions and resulted in an increase in cash coming back to the United States from Mexico, via ACS or couriers, for attempted placement in U.S. financial institutions. Law enforcement information and BSA data analysis suggest that much of this cash movement is not properly reported on a CMIR and therefore not made available in the FinCEN database for the benefit of investigators and analysts following illicit money trails.
The Director of FinCEN is authorized to issue a GTO requiring any domestic financial institution, or certain other trade or business groups, in a geographic area to obtain and report desired information. In this case, the order requires more detailed information to be reported on cash movements. A GTO is a particularly powerful and appropriate tool to narrowly address risks in certain regions without more broadly affecting commerce or business routines. FinCEN has worked in close coordination with law enforcement on this GTO, including U.S. Immigration and Customs Enforcement’s Homeland Security Investigations (HSI) and U.S. Customs and Border Protection (CBP).
Today’s announcement is directed in part to the Chief Executive Officers of ACS and other common carriers of currency to alert them to their obligations under the Order and to aid them in understanding and complying with it. If you believe your business may be affected by the Order, please contact the FinCEN Resource Center by calling 1-800-767-2825 or (703) 905-3591 or by emailing your inquiry to FRC@fincen.gov to obtain additional information. Inquiries from the press should be directed to Office of Public Affairs at (703) 905-3770.
FinCEN’s mission is to safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities.