
Ninth Circuit Blocks FinCEN's $200 Cash-Reporting Order: What the Border GTO Ruling Means for Money Services Businesses
On July 14, 2026, the Ninth Circuit upheld an injunction blocking FinCEN's border Geographic Targeting Order, which required money services businesses in ~30 ZIP codes to file Currency Transaction Reports for cash transactions as low as $200 — 50 times below the normal $10,000 threshold. The court found FinCEN likely violated the APA by skipping notice-and-comment rulemaking and ignoring compliance costs.










