Geographic Targeting Order Imposing Recordkeeping and Reporting Requirements on Certain Financial Institutions in Minnesota

Key dates

2026-08-11

Effective date of the Geographic Targeting Order

2027-02-06 Deadline

Order period ends after 180 days unless renewed

Suggested considerations

• Compliance teams may wish to identify all branches, subsidiaries, and offices in Hennepin and Ramsey Counties and map which payment flows meet the Order’s definition of a Covered Transaction.
• Firms may wish to update transaction-monitoring and customer due diligence workflows to capture the additional data elements required for bank or money transmitter reports, including beneficiary or recipient contact details and government-benefits-related funding questions.
• Operational teams may wish to confirm readiness to submit reports through the FI Portal and to generate the required CSV files using the Minnesota Fraud GTO template and naming convention.
• Records-management teams may wish to set a retention control ensuring all reports and related compliance records are preserved for five years from the last day the Order is effective.
• Banks and money transmitters may wish to review whether any existing BSA or sanctions screening processes can be leveraged to identify covered international transfers meeting the $3,000 threshold.
• Compliance teams may wish to test month-end reporting processes so filings occur by the end of the month following the month in which each Covered Transaction took place.

What changed

The Order creates a temporary, geographically targeted recordkeeping and reporting regime under 31 CFR Part 1010 for covered institutions in Hennepin and Ramsey Counties. A “Covered Business” is any bank under 31 CFR 1010.100(d) or money transmitter under 31 CFR 1010.100(ff)(5) with a branch, subsidiary, or office in the covered area. A “Covered Transaction” is a funds transfer subject to existing record retention rules under 31 CFR 1020.410(a) or 31 CFR 1010.410(e) where the payment order or transmittal order is accepted by the covered business and the transaction meets the Order’s conditions, including an originator/transmittor address in the covered area, non-public-company status, non-BSA financial-institution status, and, for banks, exclusion of certain originators under 31 CFR 1010.2

Who is affected

• Banks with a branch, subsidiary, or office in Hennepin County, Minnesota
• Banks with a branch, subsidiary, or office in Ramsey County, Minnesota
• Money transmitters with a branch, subsidiary, or office in Hennepin County, Minnesota
• Money transmitters with a branch, subsidiary, or office in Ramsey County, Minnesota

Related regulations

• 31 CFR 1010.100(d)
• 31 CFR 1010.100(ff)(5)
• 31 CFR 1010.230(e)(2)(i)-(xvi)
• 31 CFR 1010.410(e)
• 31 CFR 1020.410(a)
• 31 U.S.C. 5326
• Bank Secrecy Act