Valuta Corporation, a money services business (MSB) based in El Paso, Texas, has been run by Ashley Light’s family for over 40 years. The first MSB licensed in Texas, Valuta provides money exchange, check-cashing, and transaction services for residents who frequently travel between Texas and Mexico. Unfortunately for Valuta, it happens to have the wrong ZIP code for an MSB operating on the southern border.
In March, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a geographic targeting order (GTO) that quietly turned MSBs along the U.S.-Mexico border into surveillance hubs. The order required MSBs in specific ZIP codes along the Texas and California borders to file a currency transaction report (CTR) for any cash transaction over $200.
Under the Bank Secrecy Act (BSA), financial institutions are already required to file reports on cash transactions over $10,000. The BSA also authorizes the Treasury Department to impose additional reporting requirements to detect and prevent money laundering. Reports are required for bank checks, cashier’s checks, money orders, or traveler’s checks over $3,000, and for foreign currency exchanges over $1,000…