FinCEN on Friday issued an expanded Geographic Targeting Order (GTO) along the entire U.S.-Mexico border, requiring title insurance companies, escrow agents, and real estate attorneys in all 29 border counties to report cross-border cash movements exceeding $10,000 used for real estate purchases.
The original GTO, first issued in 2023, covered only four counties in Texas and two in California. The expansion follows a classified intelligence assessment that drug cartels are increasingly using U.S. real estate near the border to launder bulk cash proceeds from fentanyl and methamphetamine sales.
Under the GTO, covered entities must file a Currency Transaction Report (CTR) for any cash payment received from a buyer where the funds originated outside the United States, regardless of whether the cash was physically transported across the border or wired through a third country. Violations carry penalties of up to $250,000 per transaction.
Cartel real estate purchases targeted
The Drug Enforcement Administration (DEA) estimates that Mexican cartels laundered $2.3 billion through U.S. real estate in 2025, much of it concentrated in border cities like El Paso, McAllen, and San Diego. 'Cash is still king for cartels, and real estate is their preferred asset,' said DEA Administrator Anne Milgram.
The Texas Real Estate Commission opposed the expansion, arguing it would impose undue burdens on small title companies. 'We are not law enforcement,' said commission chair John B. Lacy. FinCEN responded by offering free training and a simplified electronic filing portal.
Cash is still king for cartels, and real estate is their preferred asset. This GTO closes a major loophole that allowed dirty money to buy clean property.
The GTO takes effect May 15, 2026, and will remain in force for one year, with an option to renew. FinCEN said it will publish aggregated data on cartel-related real estate purchases quarterly.
