FinCEN, Treasury attempt to clarify order aimed at Minnesota banks over fraud claims with FAQs

“Frequently asked questions” (FAQs) about the order aimed at Minnesota financial institutions were released late Tuesday by the Treasury Departments anti-financial crimes arm.

The FAQs address the “Geographic Targeting Order” (GTO) issued Jan. 9 by the Treasury, the Financial Crimes Enforcement Network (FinCEN) said. The order involved money transmitters and banks in Hennepin and Ramsey Counties of Minnesota, according to FinCEN.

“The GTO requires all banks and money transmitters located in Hennepin County and Ramsey County, Minnesota to file reports with FinCEN of certain international funds transfers of $3,000 or more,” FinCEN said in a statement. “The terms of the GTO are effective beginning February 12, 2026, and ending August 10, 2026.”

The FAQs explain what a GTO is (“an order issued by FinCEN under the Bank Secrecy Act (BSA) that imposes additional recordkeeping or reporting requirements on domestic financial institutions or nonfinancial trades or businesses in a specific geographic area.”), and offers an explanation as to why it was issued.

“Government benefits fraud is a widespread issue in Minnesota,” FinCEN claims. “Extensive schemes have fraudulently diverted state and Federal dollars meant for people who lack housing, are food insecure, have disabilities, or are otherwise eligible to receive government benefits, costing the state of Minnesota hundreds of millions, if not over a billion, dollars—a portion of which was laundered overseas. This GTO will enhance ongoing investigations, generate new leads and investigations, assist efforts to track funds laundered internationally, and facilitate efforts to recover fraudulently obtained funds.”

The list of FAQs also states that businesses affected by the GTO “means any bank, as defined in 31 CFR 1010.100(d), or any money transmitter, as defined in 31 CFR 1010.100(ff)(5), with a branch, subsidiary, or office located in the Covered Geographic Area.” The “covered area” is Ramsey and Hennepin Counties, FinCEN said.

The regulation noted by FinCEN defines “any bank” as, among others, commercial and private banks, savings and loan association, industrial bank, or credit union “organized under the law of any State or of the United States.”

Frequently Asked Questions on the Geographic Targeting Order Involving Money Transmitters and Banks in the Counties of Hennepin and Ramsey, Minnesota