9th Circuit Blocks FinCEN’s Border Cash Rule: What It Means for the Administration’s Anti-Cartel Push

Short summary

A split 9th Circuit panel affirmed a preliminary injunction blocking FinCEN's border geographic targeting order, which had lowered the cash transaction reporting threshold from $10,000 to $200 for money service businesses along the U.S.-Mexico border. The court found FinCEN likely violated the Administrative Procedure Act by skipping notice-and-comment rulemaking and failing to account for compliance costs. The ruling signals procedural limits on emergency AML tools but does not retreat from cartel-focused enforcement overall.

• •9th Circuit blocks FinCEN's $200 CTR threshold GTO for border MSBs
• •Court finds APA violation: no notice-and-comment, compliance costs ignored
• •Dissent leaves door open for FinCEN to retry with a better-supported record

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