FinCEN renews outbound-transfer reporting order for two Minnesota counties

What changed

FinCEN renewed a Geographic Targeting Order requiring covered banks and money transmitters with a branch, subsidiary, or office in Hennepin or Ramsey County, Minnesota to report specified outbound funds transfers of $3,000 or more. The order requires added originator, beneficiary, government-funds, and transfer-method data, expressly including convertible virtual currency transmissions; monthly filing, five-year retention, supervision, and agent-notification duties apply. The renewed order is effective August 11, 2026 through February 6, 2027.

Who it affects

• Banks with a branch, subsidiary, or office in Hennepin or Ramsey County, Minnesota
• Money transmitters and their agents in the covered counties
• Compliance, operations, and payment-data vendors supporting covered outbound transfers

What is still open

• Whether FinCEN will renew or expand the order after February 6, 2027
• How covered firms will validate government-benefit source information and identify international beneficiary institutions
• How firms will operationalize convertible-virtual-currency and hawala-related data fields across agents and systems

What it means for an advisor

• Determine whether any affiliated business or payment service used in a covered workflow is itself a covered bank or money transmitter; the order does not directly impose a new duty on an RIA solely because it advises a client
• Coordinate with affected custodians or payment providers on holds, information requests, record retention, and client communications for covered outbound transfers